on or before such day (net of any liabilities the partner is considered to assume or take subject to), plus (II) the aggregate amount of the partner's distributive share of loss and deductions of the partnership as of such day (determined without regard to unrealized losses resulting from revaluations of partnership property). (B) Treatment of related party borrowings For purposes of paragraph (1)(A), the amount of invested capital with respect to any applicable partnership interest shall be reduced by the amount of any applicable loan to a partner who is described in subsection (b)(1)(B). (5) Accelerated inclusion in case of disposition of applicable partnership interest (A) In general If a taxpayer who holds an applicable partnership interest sells or disposes of any portion of such interest during a taxable year in the applicable period, the amount determined under this subsection for such taxable year shall be the sum of— (i) the amount determined under paragraph (1) for the taxable year (determined as if no such sale or disposition had occurred), plus (ii) an amount equal to the product of— (I) the excess of the amount determined under clause (i) over the amount determined under paragraph (1) for the taxable year, and (II) the number of taxable years beginning after the date of the sale or disposition and before the last day of the applicable period. (B) Applicable period For purposes of this paragraph, the applicable period is the 10-year period beginning on the later of— (i) the date the taxpayer acquired the applicable partnership interest, or (ii) the last date described in paragraph (1)(B)(ii) on which there was an increase in the amount of the taxpayers applicable percentage of the aggregate invested capital of all partners of the partnership. (6) Multiple interests If at any time during a taxable year a taxpayer holds directly or indirectly more than 1 applicable partnership interest in a single partnership, such interests shall be treated as 1 applicable partnership interest for purposes of applying