The MOP Partnership Is Involved in Construction Activities During the Year, the Partnership Has an Operating Loss of 1

The MOP Partnership is involved in construction activities. On January 1 of the current year, Patricia has an adjusted basis of $600,000 for her partnership interest consisting of the following. $$\begin{array} { l r } \text { Capital account } & \$ 350,000 \\\text { Share of partnership recourse debt } & 50,000 \\\text { Share of partnership nonrecourse debt } & \underline { 200,000 } \\& \underline { \underline { \$ 600,000 } }\end{array}$$ During the year, the partnership has an operating loss of $1.2 million and distributes $60,000 of cash to Patricia. Partnership liabilities were the same at the end of the tax year, and the nonrecourse debt is not qualified nonrecourse debt. If she owns a 60% share of partnership profits, capital, and losses, and is an active (material) participant in the partnership, how much of her share of the operating loss can Patricia deduct? (Assume that Patricia is a single
taxpayer and has no business losses from other sources.) What Code provisions could cause a suspension of the loss? How would your answer change if MOP were an LLC and Patricia had not personally guaranteed any of the debt?