Appeals Case Memo, Affected ItemsPartnership: Violet PartnershipTax Year Ended: December 31, 2009I. Issue: In order to claim the partnership loss, does the partner have sufficient basis and is the partner at-risk?II. Facts: (Include brief description of documentation in the partnership file such as partner's initial and subsequent contributions to the partnership, amount of distributions from the partnership and the amount of partner's share of non-taxable income, taxable income, loss and deductions. Was the loan recourse or nonrecourse; amount of the note; did the partner bear the ultimate economic risk of loss with respect to a particular partnership liability.)III. Recommended Key Case Settlement Position: (State recommended key case position based upon partnership level activities.)