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Darius, a wealthy individual, and Hector, Inc. form a limited partnership in which they share profits, losses, and capital in a 99 percent to 1

Darius, a wealthy individual, and Hector, Inc. form a limited partnership in which they share profits, losses, and capital in a 99 percent to 1 percent ratio. The primary purpose for selecting the limited partnership vehicle is to maximize protection from personal liability, while avoiding an additional tax at the entity level. Does such an arrangement violate the anti-abuse Regulation?

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