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751 property adjusted basis allocated amount at risk apply basis adjustment capital contribution capital gain cash CCH Dec Code Sec contributed property corporation decrease deemed depreciation determined disposition distributive share election Example expenses extent fair market value gain or loss gross income guaranteed payments increase interest in partnership inventory items investment Joint Venture limited partner limited partnership liquidation loan material participation minimum gain nership nonrecourse debt nonrecourse deductions nonrecourse liability nonrecourse loan obligation ordinary income parties partner's basis partner's interest partner's share partnership agreement partnership assets partnership interest partnership liabilities partnership property Partnership Tax Reports passive activity passive income percent person proposed regulations pursuant real property recapture recognized recourse liability rental respect sale or exchange share of partnership ship substantially appreciated Tax Reform Act taxpayer TC Memo Temp tion trade or business transaction transfer treated unrealized receivables USTC