In 2012, Adrianna contributed land with a basis of $16,000 and a fair market value of $25,000 to the A&I Partnership in exchange for a 25% interest in capital and profits. In 2015, the partnership distributes this property to Isabel, also a 25% partner, in a non-liquidating distribution. The fair market value had increased to $30,000 at the time the property was distributed. Isabel’s and Adrianna’s bases in their partnership interests were each $40,000 at the time of the distribution.

a. How much gain or loss, if any, does Adrianna recognize on the distribution to Isabel? What is Adrianna’s basis in her partnership interest following the distribution?

b. What is Isabel’s basis in the land she received in the distribution?

c. How much gain or loss, if any, does Isabel recognize on the distribution? What is Isabel’s basis in her partnership interest following the distribution?

d. How much gain or loss would Isabel recognize if she later sells the land for its $30,000 fair market value? Is this result equitable?

e. Would your answers to (a) and (b) change if Adrianna originally contributed the property to the partnership in 2003? Explain.