12 February 2003 Internal T.I. 2002-0176917 - partnerships&income allocation -- summary under Paragraph 96(1)(g)

"Although it is not possible for a partner to be allocated an amount of income or loss greater than the income or loss realized by a partnership, we are of the view that, if the taxpayers relied on IT-138R to their detriment, the TSO has the discretion to accept the taxpayers' filing position for the taxation year in question."