ABC are equal owners of a limited liability company that incurs a $1 million recourse loan to purchase property. A and B each agree to guarantee 50% of the $1 million liability. C agrees to indemnify A and B if either are called on their guarantees, but only to the extent of $200,000 each.

1. How is the $1 million liability allocated for purposes of Section 752?

2. What result in (a), above, if C agrees to indemnify A and B only to the extent of $50,000 on each of their guarantees?