26 U.S.C. § 1399
Section 1399 · No separate taxable entities for partnerships, corporations, etc.
Amended 1 time on record
Applied in 26 court decisions — leading case Hall v. United States (2012)
Most recently applied in In re Schroeder Brothers Farms of Camp Douglas LLP (May 2019)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Except in any case to which section 1398 applies, no separate taxable entity shall result from the commencement of a case under title 11 of the United States Code.