A contribution of property encumbered by a liability to a partnership will not trigger the disguised sale rules if the liability is qualified whereas the disguised sale rules may be triggered if the liability is non-qualified. Assume the properties below are contributed to a partnership. Which of the following contributions appears most likely to involve non-qualified liabilities?

a contribution of land and a building to a rental partnership; the property has a value of $1,000,000 and a mortgage with a current balance of $600,000 that was use to purchase the property six years ago.

a contribution of property with a value of $400,000 that is encumbered by a loan of $50,000 that was borrowed 15 months prior to the contribution in order to substantially improve the property

a contribution of all business assets of a sole proprietorship with a total value of $250,000; business liabilities of $40,000, borrowed 15 months ago, are also contributed to the partnership

a contribution of business assets with a total value of $200,000; liabilities of $50,000, incurred nine months ago were also contributed; some of this loan was used to pay business expenses but $40,000 of the loan was used to fund a cash distribution to the contributing owner