$9-$AB equal partnership has a $$200,000$ IRC $$1231$ loss and a $$200,000$ capital loss for the

year. Partner A has $$1,000,000$ of ordinary income outside of the partnership. Partner B has

$$600,000$ of ordinary income and $$400,000$ of IRC $$1231$ gain. They decide to amend their

partnership agreement to allocate the IRC $$1231$ loss to A and the capital loss to B$.$

Does this allocation have substantiality, Yes or No$?$

No

Yes