Which of the following statements is not a requirement of the substantial economic effect test?
A.Income, gains, losses, and deductions must be allocated to the partners in accordance with their capital contributions.
B.An allocation of income must increase the partner’s capital account balance, and an allocation of deduction must decrease the partner’s capital account balance.
C.A partner with a negative capital account balance must “restore” that capital account, generally by contributing cash to the partnership.
D.On liquidation of the partner’s interest in the partnership, the partner must receive assets that have a fair market value equal to that partner’s (positive) capital account balance.
E.All of the above statements are requirements of the substantial economic effect test.
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