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An allocation is considered as substantial if all of the following occur except:A partner loses money as a result of the allocationA partner's after-tax position is not improvedA partner's economic po
An allocation is considered as substantial if all of the following occur except:
A partner loses money as a result of the allocation
A partner's after-tax position is not improved
A partner's economic position is worsened after the allocation
No partner's economic position is substantially worse after the allocation
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