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If only a portion of an allocation made to a partner with respect to a partnership taxable year has economic effect, then the portion that

If only a portion of an allocation made to a partner with respect to a partnership taxable year has economic effect, then the portion that has economic effect consists of a proportionate share of only partnership taxable income for such year and, if such portion exceeds the partnership taxable income allocation, thereafter a proportionate share of separately stated items to such partner for such year

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