I don't agree with the first sentence. Substantial economic effect is not required, and, in fact, many (and probably most) new partnerships expressly do not use those rules. And, anecdotally, I've heard that IRS would love to more effectively audit partnership allocations. It's just really hard to do.
Agree with the second and third sentences (except that the poster likely *is* following the "default rules" for partnership allocations, since the special allocations seem to track the economic arrangement). The poster could ask a lawyer to draft an operating agreement that disclaims a tax partnership and treats each business as being owned by the relevant member for tax purposes. But it's a headache, and likely expensive. The poster might consider converting to a series LLC, if that's available, with each business in a separate series; this could be a nice, simple solution for both state law and tax purposes.
Kudos to @Anonymous_ for noting the "no partnership" issue.
