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Tax Lawyer, Vol. 56, No. 2 ALLOCATION AND REALLOCATION OF PARTNERSHIP ITEMS 357 357 ALLOCATION AND REALLOCATION IN ACCORDANCE WITH THE PARTNERS’ INTERESTS IN THE PARTNERSHIP Stephen Utz* I. INTRODUCTION If a partnership agreement either fails to allocate an item of partnership incoome gain, deduction, credit, or loss, or does so invalidly, section 704(b) requiire the item to be allocated “in accordance with the partners’ interests in the partnership” (PIP). A brief portion of the section 704(b)...

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