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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.
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