26 CFR § 301.6231(c)-4

26 CFR · Internal Revenue

§ 301.6231(c)-4 — Termination and jeopardy assessment.

TitleTitle 26: Internal Revenue PartPart 301: Procedure and Administration

SourceeCFR (current through Mar 20, 2026)

This text of 26 C.F.R. § 301.6231(c)-4 (Termination and jeopardy assessment.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

26 C.F.R. § 301.6231(c)-4 (2026).

Text

§ 301.6231(c)-4 Termination and jeopardy assessment.

(a)In general. The treatment of items as partnership items with respect to a partner against whom an assessment of income tax under section 6851 (termination assessment) or section 6861 (jeopardy assessment) is made will interfere with the effective and efficient enforcement of the internal revenue laws. Accordingly, partnership items of such a partner arising in any partnership taxable year ending with or within the partner's taxable year for which an assessment of income tax under section 6851 or 6861 is made shall be treated as nonpartnership items as of the moment before such assessment is made.

(b)Effective date. This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning pri

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§ 301.6231(c)-4 Termination and jeopardy assessment.

(a) In general. The treatment of items as partnership items with respect to a partner against whom an assessment of income tax under section 6851 (termination assessment) or section 6861 (jeopardy assessment) is made will interfere with the effective and efficient enforcement of the internal revenue laws. Accordingly, partnership items of such a partner arising in any partnership taxable year ending with or within the partner's taxable year for which an assessment of income tax under section 6851 or 6861 is made shall be treated as nonpartnership items as of the moment before such assessment is made.

(b) Effective date. This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6231(c)-4T contained in 26 CFR part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50561, Oct. 4, 2001]