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James and Connor decide they want to get into the business of owning a farm. To get more land, they invite Ryan who owns the

James and Connor decide they want to get into the business of owning a farm. To get more land, they invite Ryan who owns the land that is close to the land they want to buy. This is to put Ryan's land into the partnership. All lands are close to each other and form a big open land and are worth approximately $100,000 each. As a result, James land has an adjusted basis of $20,000; Connor land has a basis of $50,000; Ryan's land, which is recently acquired, that has a basis equal to its fair market value of $100,000. Assume the partners use regulation 1.704-3(b). They form a partnership. What would be the tax consequences to each of the partners in the following alternative transactions assuming the partners outside bases in the partnership and the inside basis remain unchanged?

  1. The partnership sells their farm property contributed by James, for $100,000.

  2. The partnership distributes the property contributed by James to Ryan, six years after the partnership is formed.

  3. The partnership distributes the property contributed by Ryan to James, six years after the partnership is formed.

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