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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 biid is satisfied.
b
The economic effect equivalence provision in Treasury Regulation Section biii 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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