[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6871(a)-1]

[Page 468-469]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                 Jeopardy, Bankruptcy, and Receiverships
 
Sec. 301.6871(a)-1  Immediate assessment of claims for income, estate, 
and gift taxes in bankruptcy and receivership proceedings.

    (a) Upon (1) the adjudication of bankruptcy of any taxpayer in any 
liquidating proceeding, (2) the filing with a court of competent 
jurisdiction or (where approval is required by the Bankruptcy Act, 11 
U.S.C. Chapters 1-14) the approval of a petition of, or the approval of 
a petition against, any taxpayer in any other proceeding under the 
Bankruptcy Act, or (3) the appointment of any receiver for any taxpayer 
in a receivership proceeding before any court of the United States or of 
any State or Territory or of the District of Columbia, the district 
director shall immediately assess any deficiency of income, estate, or 
gift tax (together with all interest, additional amounts, or additions 
to the tax provided by law), determined by him, if such deficiency has 
not heretofore been assessed in accordance with law. Such assessment 
shall be made immediately, whether or not a notice of deficiency has 
been issued, and without regard to

[[Page 469]]

the restrictions upon assessment under section 6213.
    (b) As used in this section and Sec. Sec. 301.6871(a)-2 to 
301.6873-1, inclusive, the term ``proceeding under the Bankruptcy Act'' 
includes a proceeding under chapters I to VII, inclusive, of the 
Bankruptcy Act, or under section 75 or 77 (11 U.S.C. 203, 205), or 
chapters X to XIII, inclusive, of such Act, or any other proceeding 
under the Act.