Liabilities Recognized as Recourse Partnership Liabilities Under Section 752

This document contains final and temporary regulations concerning how liabilities are allocated for purposes of section 707 of the Internal Revenue Code (Code) and when certain obligations are recognized for purposes of determining whether a liability is a recourse partnership liability under section 752. These regulations affect partnerships and their partners. The text of these temporary regulations serves as part of the text of proposed regulations (REG- 122855-15) published in the Proposed Rules section in this issue of the Federal Register.