Previous columns[1] in this space have discussed the rules dealing with the allocation of income and loss for a partnership or a limited liability company taxed as a partnership, principally discussing �704(b) of the Code and regulations thereunder.[2]

This column will discuss the allocation of income and loss when there is a change in the partners’ relative interests in the partnership during a year. This can occur by the admission of new partners; the withdrawal of old partners; transfers of partnership interests; or changes in the partnership agreement.