A partnership has nonrecourse liabilities of $100,000. Partner A contributes property with a basis of $40,000 and FMV of $100,000. The property secures the $100,000 debt. Under Section 752 and Tier 2 (Section 704(c) minimum gain), how much debt is allocated to Partner A?

1. Nonrecourse Debt Allocation Tiers:<br/> - Tier 1: Partnership Minimum Gain (none here).<br/> - Tier 2: Section 704(c) Minimum Gain (taxable gain if property satisfied debt).<br/> - Tier 3: Profit share.<br/>2. Calculate Tier 2: Liability ($100,000) - Basis ($40,000) = $60,000 potential gain.<br/>3. Allocation: $60,000 of debt is allocated to Partner A.