An Introduction to Partnerships Allocations for the Exploration and Production Partnership, Part II
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Dianne Adelberg and William H. Wilson
This is the conclusion of a two-part series on partnership allocations that began in our fall/winter 2005 issue. Part I of this article discussed partnership allocations with a focus on the “substantial economic effect” rules of § 704(b) of the Internal Revenue Code and presented situations where the partner is either contributing his own capital to the partnership or the partnership has recourse debt which one or more partners are obligated to repay. This article will take a close look at more advanced aspects of partnership allocations, including nonrecourse liabilities, allocations of tax credits, and the anti-abuse rules.
An Introduction to Partnerships Allocations for the Exploration and Production Partnership, Part II. Adelberg, Dianne and Wilson, William H., Summer 2006, pp. 58‑76.