Consider whether the new partner actually acquired ownership of a capital interest,
or the validity of the transfer where the person who made the transfer retains substantial
control over the new partner's interest, such as:
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1.
Retention of management powers and control over assets essential to the business.
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2.
Limitation on the right of the new partner to withdraw or sell their interest;
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3.
Retention of control of the distribution of amounts of income;
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4.
Restrictions on the amounts of income to the donee partner.