Assume that two equal partners who are individuals and have capital account balances of $$10,000$ each. The partnership earns $$10,000$ of income. $$5,000$ of that income comes from investments producing tax exempt interest and $$5,000$ comes from taxable business income. One partner is in the top income tax bracket and the other partner will have an effective income tax rate of $0\%$ due to a net operating loss carryforward. The partnership decides to allocate all of the tax exempt interest to the partner in the high tax bracket and all of the business income to the partner who has the net operating loss carryforwards. This type of allocation of income may violate $\_\_\_\_\_\_\_\_\_\_.$

Question $11$ options:

$-$ economic effect

$-$ substantiality

$-$ a requirement to divide all types of income equally

$-$ none of the above