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LB&I Concept Unit - IRS tax forms

LB&I Concept UnitUnit NameDetermining Liability AllocationsPrimary UIL of Certain LiabilitiesLibrary LevelTitleKnowledge BasePartnerships ShelfGeneral ConceptsBookPartnership LiabilitiesChapterLiability AllocationsDocument Control Number (DCN)PAR-C-004 Date of Last Update09/15/20 Note: This document is not an official pronouncement of law, and cannot be used, cited or relied upon as such. Further, this document may not contain a comprehensive discussion of all pertinent issues or law or the IRS's interpretation of current of ContentsGeneral OverviewDetailed Explanation of the ConceptExamples of the ConceptIndex of Referenced ResourcesTraining and Additional ResourcesGlossary of Terms and AcronymsIndex of Related Practice UnitsDRAFT3 General OverviewDetermining Liability AllocationsThe Concept of liability allocation is covered under IRC 752 and the related li

Publication 541 and Treas. Reg 1.752- 2 discuss the allocation rules for recourse liabilities. A partnership liability is a recourse liability to the extent that any partner or a related person has an economic risk of loss for that liability. A partner's share of a recourse liability equals his economic risk of loss for that liability.

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