Has anyone dealt with stuffing allocation in a non-hedge fund context? It seems even in the HF world the law is fuzzy in using aggregate reverse 704c principles in stuffing allocations. Like, sure, the market is there but no authority really blessed it (other than some Cravath partner’s article in Tax Notes in 2013). If we are talking asset class that isn’t really like marketable securities but might be able to treat it similarly solely by virtue of, say, valuation on a quarterly basis (contd)

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is there an argument for stuffing in such context?

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