26 CFR § 1. 465-27 - Qualified nonrecourse financing. (a) In general Notwithstanding any provision of section 465(b) or the regulations under section 465(b), for an activity of holding real property, a taxpayer is considered at risk for the taxpayer's share of any qualified nonrecourse financing which is secured by real property used in such activity (b) Qualified nonrecourse financing secured by real property —(1) In general