2002 Ruling 2002-0156163 - PARTNERSHIP AT-RISK AMOUNT -- summary under Paragraph 96(2.2)(c)

The principal amount of promissory notes issued by limited partners to a partnership as part of the purchase price for their limited partnership interests in the partnership would reduce their at risk amount, but the at-risk amount would be restored upon the immediate assignment of the notes to a third party in payment of an obligation of the partnership to the third party.