id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-322	Hasen, David	Partnership Special Allocations Revisited	2022	53	.pdf	application/pdf	22491	954	50	Nonetheless, given the uniqueness of most positions resulting from partnership special allocations, it appears that electivity and arbitrage worries should be minimal. It is not immediately clear why partnership special allocations ought to be tolerated when the aggregate theory supplemented by non-partnership- level transactions would seem to achieve the desirable result of accounting for pre-tax economics without sacrificing tax accuracy.	cache/ftr-322.pdf	txt/ftr-322.txt