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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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