Adam contributes property with a fair market value of $3,000,000 and an adjusted basis of 1,200,000 to his partnership for a 30% interest. 12 months after the contribution, Adam receives a cash distribution from the partnership of 3,000,000. Adam would not have contributed the property if the partnership had not contractually obligated itself to make the cash distribution. The IRS will contend Adams contribution is to be treated as a disguised sale of his property to the partnership.

a) True

b) false