Allocations of Liabilities into Outside Basis, including but not limited to:

• Analyzing recourse versus nonrecouse nature of debt;
• Analyzing economic risk of loss for recourse debt;
• Allocating nonrecourse debt and deductions;
• Tracking Tufts minimum gain;
• Analyzing debt shifts under 752 and determining whether such debt shift triggers a gain;
• Converting limited liability companies into limited partnerships and vice versa and reviewing debt shifts thereto; and
• Allocating recourse debt, and shifting recourse debt to other partners for loss purposes.