Professor Borden’s article begins by establishing that tax law allows the assignment of tax items within a partnership but does not tax the assignment as a tax-item transaction. Based on this premise, the article argues that by allowing such an allocation, the partnership tax allocation rules allow partners to do what the tax law prohibits or taxes on the open market. The article also argues that the test for determining whether an allocation has substantial economic effect is a tax-centric test—the test allows tax-item allocations and then tests whether the partner to whom the allocation is made receives the economic benefit or burden that accompanies the allocation. The article suggests that more effective allocation rules would focus on the economic arrangement the partners agree to and require tax allocations to follow the partners’ apportionment of economic items. Such deal-centric rules would help eliminate internal tax-item transactions.