Ill STAT. 1030 PUBLIC LAW 105-34—AUG. 5, 1997 the 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. PART III—PROVISION RELATING TO CLOSING OF PARTNERSHIP TAXABLE YEAR WITH RE- SPECT TO DECEASED PARTNER, ETC. SEC. 1246. CLOSING OF PARTNERSHIP TAXABLE YEAR WITH RESPECT TO DECEASED PARTNER, ETC. (a) GENERAL RULE.— Subparagraph (A) of section 706(c)(2) (relating to disposition of entire interest) is amended to read as follows: " (A) DISPOSITION OF ENTIRE INTEREST. —The taxable year of a partnership shall close with respect to a partner whose entire interest in the partnership terminates (whether by reason of death, liquidation, or otherwise).". (b) CLERICAL AJ^IENDMENT. —The paragraph heading for paragraph (2) of section 706(c) is amended to read as follows: "(2) TREATMENT OF DISPOSITIONS.— ". 26 USC 706 note. (c) EFFECTIVE DATE. —The amendments made by this section shall apply to partnership taxable years beginning after December 31, 1997. Subtitle D—Provisions Relating to Real Estate Investment Trusts SEC. 1251. CLARIFICATION OF LIMITATION ON MAXIMUM NUMBER OF SHAREHOLDERS. (a) RULES RELATING TO DETERMINATION OF OWNERSHIP.— (1) FAILURE TO ISSUE SHAREHOLDER DEMAND LETTER NOT TO DISQUALIFY REIT. —Section 857(a) (relating to requirements applicable to real estate investment trusts) is amended by striking paragraph (2) and by redesignating paragraph (3) as paragraph (2). (2) SHAREHOLDER DEMAND LETTER REQUIREMENT; PEN- ALTY.—Section 857 (relating to taxation of real estate investment trusts and their beneficiaries) is amended by redesignating subsection (f) as subsection (g) and by inserting after subsection (e) the following new subsection: " (f) REAL ESTATE INVESTMENT TRUSTS TO ASCERTAIN OWNER- SHIP. — "(1) IN GENERAL.— Each real estate investment trust shall each taxable year comply with regulations prescribed by the
�
