Miguel contributed substantially appreciated property to the MR Partnership in year 1. In year 4, other property was distributed to Miguel. The partnership does not have any hot assets. Which of the following statements is most likely to be true regarding the contribution and/or distribution?

a.The partnership recognizes the precontribution gain in year 1 and allocates that gain to Miguel.

b.The partnership recognizes the precontribution gain in year 4 and allocates that gain to all the partners.

c.Miguel recognizes precontribution gain in year 4 when the second property is distributed to him.

d.Miguel recognizes the precontribution gain on an amended tax return for year 1 when the second property is distributed to him.