Brown Partnership has $3$ partners, Sally, Sam, & Trevor with the following facts:

Brown Partnership's Assets:

Tools: FMV $$700,000$; Inside Basis $$800,000$

Land: FMV $$999,999$; Inside Basis $$7,000,000$

Cash: FMV $$500,000$; Inside Basis $$500,000$

Desk: FMV $$200$; Inside Basis $$50$

Partner's Outside Basis and Capital Interest:

Sally's Outside Basis: $$450,000$

Sam's Outside Basis: $$1,000,000$

Trevor's Outside Basis: $$600,000$

If Brown Partnership distributes to Sam all of the tools as part a non$-$liquidating distribution, what will the basis of the tools be in the hands of Sam after the distribution?