William Nest operated a consulting business as a sole proprietor in 2018, generating fees of $50,000. On January 1, 2019, he decided to set up a consulting partnership with his son Wilhelm. William transferred a used computer with an adjusted basis of $10,200 and a fair market value of

$11,000 and other office equipment with an adjusted basis of $12,250 and a fair market value of $14,000. William also felt that he had generated goodwill with a value of $30,000 that was supported by a recent bona fide offer for his consulting business.

On January 1, 2019, William gave his son Wilhelm $55,000, which he contributed to the new partnership, Will and Wile, for a one-half interest. The gross earnings of the new partnership for 2019 totalled

$75,000—$50,000 from William’s contacts and $25,000 from Wilhelm’s contacts. The net income was $60,000. In anticipation of Wilhelm’s growing contribution to future earnings, the agreement provides for equal division of profit. What is Wilhelm’s basis for his interest immediately after his cash contribution to the partnership? How will the IRS probably require that the partnership earnings be divided?