Howard E. Abrams (Emory) has published Nonrecourse Liabilities Included in Partners’ Basis, 108 Tax Notes 1301 (Sept. 12, 2005), also available on the Tax Analysts web site as Doc 2005-18146, 2005 TNT 176-29.  Here is the Summary of Conclusion:

The Joint Committee on Taxation staff report, Options to Improve Tax Compliance and Reduce Tax Expenditures (February 2004) [blogged here], was written at the request of members of Congress seeking to reduce taxpayer noncompliance with existing substantive law. The proposal to exclude nonrecourse indebtedness shares from outside basis — while described as a mere "backstop" to the proposed change to the nonrecourse deduction allocation rules — constitutes a major and unwarranted shift from law settled and relied on for almost 60 years. That alleged "backstop" proposal would work a radical change in the taxation of partners and partnerships and would discourage the use of the partnership form in many circumstances including the holding and operating of real estate. The proposal should be rejected.