SPECIAL RULES FOR ADMINISTRATIVE ADJUSTMENT REQUESTS WITH RESPECT TO BAD DEBTS OR WORTHLESS SECURITIES.

SEC. 1243. SPECIAL RULES FOR ADMINISTRATIVE ADJUSTMENT REQUESTS WITH RESPECT TO BAD DEBTS OR WORTHLESS 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.— (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 enactment.—In the case of that portion of any request (filed before 111 STAT. 1030the date of the enactment of this Act) for an administrative adjustment which relates to the deductibility of a debt as a debt which became worthless or the deductibility of a loss from the worthlessness of a security— (A) paragraph (2) of section 6227(a) of the Internal Revenue Code of 1986 shall not apply, (B) the period for filing a petition under section 6228 of the Internal Revenue Code of 1986 with respect to such request shall not expire before the date 6 months after the date of the enactment of this Act, and (C) such a petition may be filed without regard to whether there was a notice of the beginning of an administrative proceeding or a final partnership administrative adjustment.