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Why all the fuss for limitation of allocations among partners when using the rules for Internal...

Why all the fuss for limitation of allocations among partners when using the rules for Internal Revene Code Section 704?

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The determination of distributive share of income, gain, loss deduction, or credit (or item thereof) among partners under Internal Revenue Code Section 704 is not conclusive as to the tax treatment of a partner in regard to the distributive share. It causes constant tension and uneasiness between the aggregate and entity models of a partnership which runs through all of partnership tax law. Consequently creates a fuss for limitation of allocations among partners when applying Section 704.

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