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substantial economic effect, and that there is no meaningful
discrepancy between the economic effect of and of the tax
accounting for petitioner's participation as a partner of
Pecaris.
We need not accept petitioners' invitation to engage in an
extended substantial economic effect analysis of the Pecaris
partnership agreement. We don't have here the usual situation
that section 704(b) and the regulations thereunder are designed
to deal with, in which the taxpayer is trying to justify a
special allocation provided by the partnership agreement. Here
we have a common garden variety partnership agreement with a
straightforward conventional provision for sharing profits and
losses that petitioners are asking us to disregard. The absence
of any agreement among the Pecaris partners modifying the general
profit and loss sharing provisions of the Pecaris partnership
agreement precludes any special allocation of the gain from the
sale of the Mall away from petitioner. See Deauville Operating
Corp. v. Commissioner, T.C. Memo. 1985-11.
Petitioner presses the argument that the Pecaris partners'
capital accounts were not kept in accordance with the section
704(b) regulations, sec. 1.704-1(b)(2)(ii)(b)(1), Income Tax
Regs., that liquidating distributions were not required to be
made in accordance with those regulations, sec. 1.704-
1(b)(2)(ii)(b)(2), Income Tax Regs., and that there was no
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