Proceedings from the 1984 Tax Institute Symposium: Partnerships: Special Allocations Under the New Regulations, The Proposed Regulations or Whatever

This article discusses Section 704 of the Internal Revenue Code and the 1984 proposed regulations related to the section. It looks at the major test of the regulations, that an allocation will be approved if it has substantial economic effect. It examines the two parts of this - that the allocation has to have an economic effect, and that the economic effect has to be substantial