In 1988 Owner A purchases parcel A (2 acres) for $100,000 ($50K per acre) In 1995 Owner B purchases parcel B (2 acres) for $300,000 ($150K per acre) In 2009 Owner C purchases parcel C (4 acres) for $400,000 ($100K per acre) In January 2012 Owners A, B, and C contribute their land parcels into ABC LLC. At the time of