Joint and several liability holds partners and members responsible for firm tax, interest and penalties despite discontinuance or reconstitution.

If a firm, association or HUF discontinues business, tax, interest or penalty up to discontinuance may be assessed as if no discontinuance occurred, and every partner or member at that time remains jointly and severally liable for those liabilities whether determined before or after discontinuance. Similar joint and several liability attaches where a firm or association is reconstituted, dissolved, or where a HUF effects partition. A limited liability partnership is treated as a firm for these purposes.

---

---

---