ORDER

John and Barbara Camacho (“Camac-hos”) and David and June Raihl (“Raihls”) seek reconsideration of certain Orders of this Court denying their challenge to certain tax assessments. Docket Nos. 55 and 56; see, e.g., D.Ak. LR 7.1(1). The Camachos and Raihls argue that this Court misconstrued the record and overlooked a favorable factual determination by the bankruptcy court. Specifically, they contend that the Government. conceded and the bankruptcy court found that the Government conducted an investigation of the top-tier partnerships involved in this case, and in connection with that investigation requested and was provided with information regarding the indirect partners in the various top-tier partnerships. In the view of the Camachos and Raihls, this knowledge should, consistent with this Court’s legal analysis, have triggered a duty *116to specifically notify the indirect partners of the audit of the top-tier partnerships. The Camachos and Raihls misunderstand the Court’s reasoning.

The Court concluded that the statutory scheme properly put the burden on the tax matters partners of pass-through partnerships to notify their partners of audits regarding top-tier partnerships. In order for an indirect partner to gain a place on the mailing list, it was necessary for the indirect partner, either personally or through an authorized agent, to notify the Government that he was an indirect partner and had a mailing address, and that he wished to be notified of audits regarding the top-tier partnership so that he could participate in any proceedings before the agency or the court. Thus, the fact that agents of the pass-through partnerships may have responded to Government inquiries by furnishing the names and addresses of indirect partners would be irrelevant to this Court’s decision unless the response carried with it a specific request to notify the indirect partners in the event of an audit. Of course, no specific form of notification was required prior to the effective date of the new regulations. But whatever form the notification took, such notice to the Government would have had to have contained a specific request to be notified of top-tier partnership audits. The fact that the Ca-machos and the Raihls did not monitor the activities of the top-tier partnerships makes it unlikely that they, either personally or through an agent authorized by them, communicated a request to the Government to participate in proceedings involving the top-tier partnerships.

The Raihls’ also argue that this Court failed to adequately address their argument that as direct partners in Gran Esperanza they were entitled to both an NBAP and an FPAA, and that since they only received an FPAA, the Government’s audit is invalid as applied to the Raihls. The bankruptcy court agreed that the Raihls were entitled to both notices and only received one. However, it concluded that the Raihls’ failure to make an election under section 6223(e) denied them a remedy at this late date. This Court considered the Raihls’ argument. See Docket No. 49 at 6 n. 8. Essentially, this Court assumed that the Raihl’s had not received the proper notice and looked to the statutory remedy. Congress allowed taxpayers situated similar to the Raihls two choices: 1) default — the taxpayer could choose to be bound by the decision at the partnership level despite the lack of notice; or 2) election — the taxpayer could elect to treat the affected items as non-partnership items, in which case the statute of limitations would be extended and the matter would be resolved at the Raihls’ level. The Court did not recognize a third possibility, that the Raihls could escape a reconsideration of their tax returns entirely. Since the Raihls did not elect to treat the items as non-partnership items and litigate at their own level, this Court affirmed the bankruptcy court decision that they were left with the default result.1

*117The Camachos argue that under general partnership law knowledge of the managing partners of the pass-through partnerships should not be imputed to the indirect partners because the managing partners were perpetrating a fraud and in fact have been convicted and imprisoned for that fraud. More important, the Camachos continue, the Government was contemplating criminal proceedings against the principals of the pass-through partnerships at the time the notices required by the statute were given and thus the Government’s knowledge of the criminal activity should have alerted it to the need to personally notify the various indirect partners. See, e.g., U.P.A. § 12; AS 32.05.070; Utah Code Annot. 48-1-9. It is true that where a partner engages in fraudulent conduct that does not benefit the partnership or the partners in any way, his knowledge is not imputed to the innocent partners. Where, however, his fraud is intended to benefit the partnership, his knowledge is imputed to the other partners, even if they are ignorant of the fraud. Friend v. H.A. Friend & Co., 416 F.2d 526, 533 (9th Cir. 1969). While this issue was not raised below, and the record has not been fully developed, it appears that the fraud in this ease was directed at the Government and the parties guilty of the fraud were at least attempting to benefit the partnerships by their conduct. If this is true, their knowledge would be imputed to their innocent partners.

IT IS THEREFORE ORDERED:

The motions for reconsideration at Docket Nos. 55 and 56 are DENIED.