SKOPIL, Circuit Judge:
We must decide in this case whether taxpayers, limited partners in five similar partnerships engaged in oil and gas drilling operations, were "at risk" pursuant to 26 U.S.C. § 465 on certain recourse notes and thus entitled to deduct distributive shares of non-cash partnership losses. The Tax Court in a reviewed, split decision held that each taxpayer was at risk only to the extent of actual cash contribution. Pritchett v. Commissioner...
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