Assume that a partnership consists of two individuals, Jena and Barbara, who each own 50% of...
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Assume that a partnership consists of two individuals, Jena and Barbara, who each own 50% of partnership profits. Which of the following allocations, based on the description, may lack substantiality? -allocating all of the tax-exempt interest income to a Jena who is in a high tax bracket and an equal differential amount of ordinary income to a Barbara who is in a low tax bracket -allocating $200,000 (100%) of the ordinary income (for both book and tax purposes) to Barbara who has a net operating loss carryforward in excess of $200,000 and offsetting that deduction by making a special allocation of $200,000 to Jena in the following year. -allocating all of the long-term capital gain income to a Jena who has capital losses in the current year while allocating an equal differential amount of ordinary income to a Barbara - All of these appear possibly to lack "substantiality" Assume that a partnership consists of two individuals, Jena and Barbara, who each own 50% of partnership profits. Which of the following allocations, based on the description, may lack substantiality? -allocating all of the tax-exempt interest income to a Jena who is in a high tax bracket and an equal differential amount of ordinary income to a Barbara who is in a low tax bracket -allocating $200,000 (100%) of the ordinary income (for both book and tax purposes) to Barbara who has a net operating loss carryforward in excess of $200,000 and offsetting that deduction by making a special allocation of $200,000 to Jena in the following year. -allocating all of the long-term capital gain income to a Jena who has capital losses in the current year while allocating an equal differential amount of ordinary income to a Barbara - All of these appear possibly to lack "substantiality"
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