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Transitory allocations

Transitory allocations
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transitory allocations

those allocations that occour in different tax years.generally it involves an original allocation in one year and then an offsetting allocation in later year.

  • possibility within five taxable years that an original allocations will be largely offset by one or more offsetting allocations.
  • "strong liklihood"that partner's capital accounts will emerge unaffected.
  • partners enjoy reduction in total tax liability for period involved.

lack economic effect.

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