OPINION
COHEN, Judge:
Respondent determined a deficiency of $152,613 in petitioners' 1981 Federal income taxes. After concessions, the issues for decision are as follows:
(1) To what extent is petitioner's amount at risk increased by virtue of assuming the primary obligation of the principal, but not the interest, of a recourse purchase note bearing nonrecourse interest.
(2) If we decide the first issue in favor of petitioners, whether...
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