- 22 - that petitioner would be ultimately liable to make payments on Petunia’s debt obligations to F.S. Venture. Notwithstanding the recourse nature of the underlying third- party loan between MHLC and Alanthus, other significant features of the transaction, as explained above, immunized petitioner and the other limited partners of Petunia from any realistic possibility of liability with regard to the Partnership Note. We conclude that petitioner is to be treated as not at risk within the meaning of section 465 with respect to his allocable share of the Partnership Note. To reflect the foregoing, An appropriate order will be issued.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
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