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Which of the following will not allow a special allocation to be considered as substantial? A. The special allocation is considered to be a pro

Which of the following will not allow a special allocation to be considered as substantial? A. The special allocation is considered to be a pro rata distribution. B. The special allocation is not considered to be a shifting or transitory allocation. C. The special allocation is provided for in the partnership agreement. D. The special allocation violates the overall tax effect rule.

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