Section 7. TEFRA Bankruptcy›4.31.7 TEFRA Bankruptcy›The Effect of TEFRA Bankruptcy and TEFRA›Analyze Case and Determine Which Partnership Tax Years Convert
Chapter 12 Bankruptcy Conversion Exception
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
Unlike a Chapter 13 proceeding, no provision exists for filing claims for post petition income taxes in a Chapter 12 bankruptcy of an individual. For example, if an individual files a Chapter 12 petition on September 15, 1990, the partnership items for 1990 will not convert because no claim could be filed in the bankruptcy case for those items, and the partnership’s 1990 taxable year has not ended on or before September 15, 1990. The 1989 year would be the latest year for which a claim could be filed, and only the 1989 and prior year(s) would convert regardless of how long the bankruptcy is in existence.
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