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Same way. If they aren't at risk they can't claim the loss.
I guess my real problem is that most of the states begin with the federal number and ask for total sales in that state vs. total sales. These states have gotten k1s so I assume I have to do a tax return, do I use zero as the sales receipts in those states or do I need to get actual sales amounts from the k-1 issuer? And if I do that the client would owe tax on income earned in the home state not the non resident states....
Is the partnership related to their S Corp business? Or is it an investment?
Maybe the income/loss is allocable instead of having to part of the apportioned income.
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