Page:United States Statutes at Large Volume 111 Part 1.djvu/1053

 PUBLIC LAW 105-34—AUG. 5, 1997 111 STAT. 1029 "(B) no action is brought under paragraph (1) during the 60-day period described therein with respect to such taxable year which is not dismissed, such petition shall be treated for purposes of paragraph (1) as filed on the last day of such 60-day period.". (b) EFFECTIVE DATE. —The amendment made by this section 26 USC 6226 shall apply to petitions filed after the date of the enactment of note. this Act. SEC. 1241. BONDS IN CASE OF APPEALS FROM CERTAIN PROCEEDING. (a) IN GENERAL. —Subsection (b) of section 7485 (relating to bonds to stay assessment of collection) is amended— (1) by inserting "penalties," after "any interest,", and (2) by striking "aggregate of such deficiencies" and inserting "aggregate liability of the parties to the action". (b) EFFECTIVE DATE.—The amendment made by this section 26 USC 7485 shall take effect as if included in the amendments made by section note. 402 of the Tax Equity and Fiscal Responsibility Act of 1982. SEC. 1242. SUSPENSION OF INTEREST WHERE DELAY IN COMPUTA- TIONAL ADJUSTMENT RESULTING FROM CERTAIN SETTLEMENTS. (a) IN GENERAL.— Subsection (c) of section 6601 (relating to interest on underpayment, nonpayment, or extension of time for payment, of tax) is amended by adding at the end the following new sentence: "In the case of a settlement under section 6224(c) which results in the conversion of partnership items to nonpartnership items pursuant to section 6231(b)(1)(C), the preceding sentence shall apply to a computational adjustment resulting from such settlement in the same manner as if such adjustment were a deficiency and such settlement were a waiver referred to in the preceding sentence.". (b) EFFECTIVE DATE.— The amendment made by this section 26 USC 6601 shall apply to adjustments with respect to partnership taxable note. years beginning after the date of the enactment of this Act. SEC. 1243. SPECIAL RULES FOR ADMINISTRATIVE ADJUSTMENT REQUESTS WITH RESPECT TO BAD DEBTS OR WORTH- LESS SECURITIES. (a) GENERAL RULE.— Section 6227 (relating to administrative adjustment requests) is amended by adding at the end the following new subsection: "(e) REQUESTS WITH RESPECT TO BAD DEBTS OR WORTHLESS SECURITIES.— In the case of that portion of any request for an administrative adjustment which relates to the deductibility by the partnership under section 166 of a debt as a debt which became worthless, or under section 165(g) of a loss from worthlessness of a security, the period prescribed in subsection (a)(1) shall be 7 years from the last day for filing the partnership return for the year with respect to which such request is made (determined without regard to extensions).". (b) EFFECTIVE DATE. — 26 USC 6227 (1) IN GENERAL.— The amendment made by subsection (a) note, shall take effect as if included in the amendments made by section 402 of the Tax Equity and Fiscal Responsibility Act of 1982. (2) TREATMENT OF REQUESTS FILED BEFORE DATE OF ENACT- MENT. —In the case of that portion of any request (filed before

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