A partner who contributes appreciated property should be aware that:

A. There may be a requirement to always recognize any built-in gain and pay tax in the year of the contribution.

B. If there are any planned distributions within the first two years following the contribution, there is potential for recharacterization as a disguised sale.

C. Distributions within eight years of a contribution of appreciated property could result in the recognition of built-in gain.

D. The terms of a partnership agreement cannot include prohibitions of any distributions related to contributed property.