id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-6680	Zuo, Zhiyuan	A GAIN MUST LIE WHERE IT FALLS: MATCHING TAX WITH ECONOMICS IN SUBCHAPTER K	2020	38	.pdf	application/pdf	22073	966	50	§ 1.704-1(b)(2)(ii)(i), part of the SEE safe harbor, has been applied to justify partnership allocations. This is because it is now harder to create an artificial net loss for a partner through a special allocation of nonrecourse deductions.37 Treasury’s position on the allocation of partnership nonrecourse deductions appears to be a compromise between complying with the Tufts doctrine and reducing its harmful impact during partnership allocations.	cache/taxlaw-6680.pdf	txt/taxlaw-6680.txt