Matthew and Mark form OWL Five partnership and each contribute $50,000 cash. OWL Five purchases $50,000 of stocks and $50,000 of tax-exempt bonds. There is a strong likelihood that the stocks and bonds will produce equal amounts of taxable dividends and tax-exempt interest income. In Year One, Matthew expects to be in a higher marginal tax bracket the Mark. In Year One the partners agree to allocate the tax-exempt interest 90% to Matthew and 10% and 10% to Mark, and to allocate the taxable dividends 10% to Matthew and 90% to Mark. The allocation has economic effect. Is the allocation substantial? Explain

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Substantiality Analysis of OWL Five Partnership Allocation The allocation of the taxexempt interest ... View the full answer