Joint and several liability: partners and members remain liable for firm tax, interest and penalty despite discontinuance or reconstitution. If a firm, association of persons or Hindu Undivided Family discontinues business, tax, interest and penalty up to discontinuance may be determined as if no discontinuance occurred, and every partner or member at that time remains jointly and severally liable for payment; similar joint and several liability attaches on change of constitution, dissolution, or HUF partition. A limited liability partnership is treated as a firm for these purposes.