Eric Sloan, James Jennings, and David Horton Write About Allocation of Nonrecourse Partnership Liabilities in the Absence of Default Rules for TAXES – The Tax Magazine

Article | March 11, 2026

TAXES – The Tax Magazine

Partners Eric Sloan and James Jennings and associate David Horton have written for TAXES – The Tax Magazine [PDF]: “Unlike the regulations addressing the allocation of partnership recourse liabilities, the regulations addressing the allocation of nonrecourse liabilities are brief, leave many gaps to be filled, and provide — implicitly and explicitly — taxpayers with considerable latitude. As a result, it simply is not possible for a taxpayer to comply with the regulations without exercising judgment and discretion.”

Eric Sloan, James Jennings, and David Horton Write About Allocation of Nonrecourse Partnership Liabilities in the Absence of Default Rules for TAXES – The Tax Magazine

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