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    Partnership Sale

    Regarding a partnership, Nonrecourse Debt increases outside basis for the applicable partner but does not increase at risk basis. If the Partners interest in the Partnership is sold, does the nonrecourse debt increase basis for capital gain or loss purposes or is it excluded?

    #2
    See:

    Instructions for Form 6198

    also, TheTaxbook section 7 at risk rules
    Always cite your source for support to defend your opinion

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