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Observation: Considering that promissory notes from purchasers are generally dealt with as cash when analyzing The idea with the home in the customer's hands, It appears reasonable to take care of a note like cash when pinpointing the basis from the assets transferred in the Sec. 351 Trade.

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(2) Exception for nonrecourse liabilityThe level of the nonrecourse liability handled as described in paragraph (1)(B) shall be reduced from the lesser of— (A) the amount of this kind of liability which an owner of other belongings not transferred into the transferee in addition to subject matter to these legal responsibility has agreed Along with the transferee to, and is anticipated to, satisfy; or

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