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Section 7. TEFRA Bankruptcy›4.31.7 TEFRA Bankruptcy›Note:

Subchapter S Corporations

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

S Corporations are pass-through entities that are generally nontaxable, but can also be taxable entities for certain purposes. The bankruptcy of a tier or pass-thru partner will have its own partnership items converted to nonpartnership items while any items of income, gain, losses, deductions and credits that flow through the S Corporations will remain partnership items. The bankruptcy of a tier, or pass-thru partner, will only affect its own taxable partnership items. It will not affect the underlying indirect investors.

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