Not george,  ....

I think it through with DRs and CRs.  The ptsp gets the debit, which is an expense, while the credit is either a loan payable, a contribution, or a reduction to distributions.  Either of these 3 choices increases the partner's basis. Does this make sense?

I don't think this qualifies as an amount at-risk because this is a type of non-recourse loan, though not really a loan.  That is my reasoning.

I like your question.

From the 6198 instructions: Amounts Not at Risk
You are not considered at risk for any of the following.
1. Nonrecourse loans used to finance the activity, to acquire property used in the activity, or to acquire your interest in the activity (unless the nonrecourse loan is secured by your own property that is not used in the activity)

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