26 February 1990 T.I. (July 1990 Access Letter, ¶1343)

The cost to an investor is determined in accordance with GAAP including, in the case of a limited partnership interest, any loans or other financing required by the investor in order to acquire his limited partnership interest.

The reference to prescribed benefits contained in subparagraph (b)(ii) does not limit the calculation to those benefits expected to be received or enjoyed in the initial four-year period. Additional funds which the investor is required to invest in a limited partnership will be included in the cost of his interest provided that the funds are paid within four years after the day the interest was originally acquired.

Where the liability for repaying all cash guarantees rests with the investor and the guarantees are structured as loan arrangements, it is still a question of fact whether the arrangements will result in the investor receiving a return of a portion of his outlays. Where an investor is ultimately fully liable to repay a mortgage guarantor for any funds laid out, the mortgage guarantee does not reduce the impact of any loss which the investor may sustain.