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A and B form the equal AB partnership. A is a cash basis individual taxpayer and B is an accrual basis taxpayer. As an individual,
A and B form the equal AB partnership. A is a cash basis individual taxpayer and B is an accrual basis taxpayer. As an individual, long-term capital gains will be taxed at a preferential rate for A. The AB partnership expects to have equal amounts of ordinary income and capital gains every year. The partnership agreement provides that A will be allocated all of the capital gains and B will be allocated all of the ordinary income. Capital accounts are properly maintained, any distributions in liquidation will be made in accordance with each partners capital account, and both partners are required to restore deficit capital accounts upon liquidation. Will this allocation have substantial economic effect? A Why or why not
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