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33) Nevertheless, to the extent a taxpayer can demonstrate that the "complete" dominion and control test"(34) is met with respect to a back-to-back structure, it could present an interesting alternative for the taxpayer.
However, a more interesting question remained for the court--the determination of the character of the abandonment loss in a situation in which the partnership had no liabilities.
An interesting thing happened to tax-exempt interest in 1986 - it potentially became taxable.