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If a partnership does not satisfy the requirements of the primary economic effect test, partnership allocations still can have economic effect if which of the

If a partnership does not satisfy the requirements of the primary economic effect test, partnership allocations still can have economic effect if which of the following is true:
a.
The alternate economic effect test in Treasury Regulations Section 1.704-1(b)(2)(ii)(d) is satisfied.
b.
The economic effect equivalence provision in Treasury Regulation Section 1.704-1(b)(2)(ii)(i) is satisfied.
c.
Partnership income and loss is allocated pro rata in accordance with deficit restoration obligation.
d.
Both (a) and (b)

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