a$)$ What is the essential concern motivating the requirement that allocations to partners have Substantial Economic Effect?

b$)$ Describe the criteria under the basic test for Economic Effect and illustrate where necessary.

c$)$ Distinguish the Alternate Test for Economic Effect from the basic test and provide an illustration of how that would work.

d$)$ What is the meaning of "Substantiality" and how might partnerships use special allocations to violate that requirement? Give an example.

e$)$ What may the IRS do if a partnership's allocations violate Substantial Economic Effect?