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Tax Lawyer, Vol. 56, No. 1 DOES REGULATION SECTION 1.704-2 PERMIT SPECIAL ALLOCATIONS 155 155 DOES REGULATION SECTION 1.704-2 PERMIT SPECIAL ALLOCATIONS OF NONRECOURSE DEDUCTIONS ATTRIBUTABLE TO EXCULPATORY LIABILITIES? Bethany Atkins Rice* I. INTRODUCTION The section 704(b) regulations of the Internal Revenue Code that allocate nonrecourse deductions for partnerships were originally drafted in tandem with the section 752 regulations, which allocate nonrecourse debt for basis purposes.1 Combined...

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