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Partner C has a capital loss of $90,000 and has knowledge that the partnership will have large capital gains for the year. The other partner,

Partner C has a capital loss of $90,000 and has knowledge that the partnership will have large capital gains for the year. The other partner, D, is in a low tax bracket. Which of the following might not be considered as a shifting allocation?

A. Allocations of capital gains to C and interest income to partner D

B. Allocations of capital gains to C and ordinary income to partner D

C. Allocations of capital losses to D and Section 1231 gains to partner C

D. Allocations of depreciation to C

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