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The obligation would be paid to K.K.R. out of “realization proceeds allocable to the fund” upon the sale of fund investments, it said.

Tentative innovation profit is generally equal to its gross receipts from qualified property less deductions allocable to those receipts.

Consequently, the couple suffered a substantial loss allocable to the stock.

The Final Regulations provide that taxpayers may use any reasonable method to determine what portion of the deduction for state income taxes is properly allocable to NII.

Investment interest, up to the amount of the taxpayer’s NII, is allowed as a properly allocable deduction.