Darryll K. Jones (Pittsburgh) has published Nonrecourse Debt: Newspeak in the Tax Code, 106 Tax Notes 117 (2005) as part of his "K Rations" series of articles on partnership tax isues.  Here is part of the Introduction:

The tax code (broadly defined to include statutes, regulations, and interpretive guidance from all sources) is talking from both sides of its proverbial mouth, using oxymoronic newspeak such as ‘‘nonrecourse deductions’’ and ‘‘partnership minimum gain’’ to obscure the plain fact that spending other people’s money neither results in negative income to, nor justifies a deduction, for the spender. We would do well by ridding the code of newspeak. Basis, like religion, is highly personal. It is one person’s previously taxed (or exempted) wealth embodied in property. The expenditure of other people’s money should justify negative income — a deduction — only if the acquisition of other people’s money first resulted in positive income — inclusion in gross income. I propose that a nonrecourse borrower should pay tax on the receipt of nonrecourse loans and anything that looks like a nonrecourse loan — such as the transfer of a contingent liability.

The article also is available on the Tax Analysts web site (Doc 2005-23438, 2005 TNT 2-40.