Nonrecourse liabilities do not count for purposes of at-risk.
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2.
Which investors do, with nonrecourse loans.
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3.
Isaacson reasons the terms of the loans made them "nonrecourse" (meaning the employee's other assets weren't at risk) and that 1971 IRSregs on nonrecourse loans mean the shares shouldn't have been valued and taxed until the margin call, when they were worth less.