-26-                                          
          acquired properties with nonrecourse debt, the partnership's                
          deduction of expenses associated with these properties--such as             
          expenses for depreciation--may lead to a situation where the amount         
          of nonrecourse debt exceeds the partnership's basis in the                  
          properties securing that debt.    Such  deductions--called                  
          "nonrecourse deductions"--per se do not have economic effect.  The          
          lack of economic effect arises from the fact that the lender, and           
          not the partnership or its partners, bears the economic risk of             
          loss with respect to the nonrecourse deductions.                            
                    2.  Minimum Gain Chargeback                                       
               As applicable to the taxable year at issue, there are                  
          temporary regulations governing the allocation of deductions                
          attributable to nonrecourse debt.  These regulation provisions are          
          set forth as sections 1.704-1T(b)(4) and (5), Temporary Income Tax          
          Regs., 53 Fed. Reg. 53162-53173 (Dec. 30, 1988). The regulatory             
          provisions involve the concepts of "minimum gain" and "minimum gain         
          chargebacks".  These provisions represent the application of the            
          principle of Commissioner v. Tufts, supra, in a partnership                 
          context.                                                                    
               "Minimum  gain"  is  created  when  a  partnership  claims             
          deductions, such as deductions for depreciation, that decrease the          
          partnership's basis in a given property to an amount less than the          
          balance of the nonrecourse debt incurred in the acquisition of that         
          property.                                                                   
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