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Assume the same facts as previously stated under the original fact pattern. Consider the second step in allocating nonrecourse liabilities. Per Treasury Regulation Section 1.752-3(a)
Assume the same facts as previously stated under the original fact pattern. Consider the second step in allocating nonrecourse liabilities. Per Treasury Regulation Section 1.752-3(a) nonrecourse debt is allocated among the partners according to a three part ordering rule, the second step of which is to allocate a portion of the nonrecourse liability to each partner in the amount of any taxable gain that would be allocated under Code Section 704(c) if the property subject to nonrecourse debt were disposed of in consideration for the debt and no other consideration. True/False: In this case, the second step allocation would result in no debt allocation among the partners
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