The MOP Partnership is involved in leasing heavy equipment under long-term leases of five years or more.Patsy has an adjusted basis for her partnership interest on January 1 of the current year of $600,000,consisting of the following:
During the year,the partnership has an operating loss of $1.2 million and distributes $60,000 of cash to Patsy.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 a material participant in the partnership,how much of her share of the operating loss can Patsy deduct? What Code provisions could cause a suspension of the loss?
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