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752), A would be obligated to contribute $9,000; the deficit balance would not exceed this obligation and the allocation would hive economic effect.
The trustee would distribute the proceeds to the surviving shareholders, who would be obligated to purchase the shares under the shareholder agreement.
For partners not obligated to restore deficit capital account balances, or obligated to restore only a limited dollar amount of deficit capital account balances, the alternate test for economic effect substitutes two additional requirements for the unlimited deficit restoration requirement.