LEVAL, Circuit Judge:
This appeal requires us to examine for the second time the propriety of a partnership's allocation (for tax purposes) of virtually all of its taxable income to two ostensible partners, both foreign banks, which are not subject to tax by the United States. The issues on appeal are (1) whether the foreign banks qualify as partners in the partnership under Internal Revenue Code ("I.R.C.") § 704(e)(1), and (2), if not, whether a penalty was...
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