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underlying economic arrangement of the partners. Sec. 1.704-
1(b)(5), Example (4)(ii), Income Tax Regs. Petitioner failed to
address whether or not the economic effect of the allocation was
substantial. Consequently, we conclude that petitioner has
failed to establish that the economic effect of the allocation
was not substantial. Accordingly, we sustain respondent’s
determination.
Contentions we have not addressed are irrelevant, moot, or
meritless.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011