economic risk of loss, known as “nonrecourse liabilities,” will be treated as a deemed distribution of cash to that Partner. A decrease in a Partner's percentage interest in KUE because of KUE’s issuance of additional limited partner units (“Limited Partner Units"} would decrease such Partner's share of Company nonreccurse liabilities, if any, and thus would resuit in a corresponding deemed distribution of cash. Treatment of In-Kind Distributions. KUE's distribution of property (other than cash) to a Partner generally will not be taxable to the Partner unless the property is a “marketable security” and the exceptions to the requirement for recognition of gain upon distributions of marketable securities do not apply. Marketable securities, for these purposes, include actively traded securities or equity interests in another entity that are readily convertible into or exchangeable for cash or other marketable securities. If the distributed property constitutes a marketable security, the property would be treated as cash and the Partner would recognize gain, but not loss, to the extent described above. Basis of Common LP Units. A Limited Partner will have an initial tax basis for its Common LP Units equal to the amount it paid for the Common LP Units plus its share of Company nonrecourse liabilities, if any. That basis will be increased by the Limited Partner’s share of Company income and by any increases in its share of Company nonrecourse liabilities, if any. That basis will be decreased, but not below zero, by distributions from KUE, by the Limited Partner's share of KUE losses, by any decrease in its share of Company nonrecourse liabilities, if any, and by its share of Company expenditures that are not deductible in computing KUE’s taxable income and are not required to be capitalized. Limitations on Deductibility of Company Losses. The deduction by a Limited Partner of its share of Company lasses will be limited to the adjusted tax basis in its Common LP Units. Li