Although a partner's distributive share of income,deductions,losses,and credits is generally determined by partnership agreement,special allocation provisions restrict the partners' freedom to shift some tax benefits among partners.

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Although partners can agree to allocate income, deductions, losses, and credits among themselves in a way that differs from their ownership percentage, there are certain limitations on this ability. These limitations are referred to as special allocation provisions and aim to prevent partners from unfairly shifting tax benefits among themselves.

Although a Partner's Distributive Share of Income,deductions,losses,and Credits Is Generally