Tammie contributes $50,000 cash in exchange for a 25% interest in the profi ts and capital of the XYZ Partnership. The partnership has $300,000 of recourse debt and $100,000 of nonqualifi ed nonrecourse debt. The partnership has a loss of $800,000 for the year. How much of the loss will Tammie be able to deduct, assuming she is allocated 25% of the liabilities and the partnership is not a passive activity?