Partners A and B form a partnership where each receive a 50% interest in capital and profits. Partner A contributes cash of $25,000 and land valued at $25,000. Partner A has a basis in the land of $20,000 and has held it for two years. Partner B contributes equipment (with a basis to B of $15,000 and a fair market value of $30,000) and inventory (with a basis to B of $10,000 and a fair market value of $20,000). Partner B would recognize Section 1245 gain of $15,000 on the hypothetical sale of the equipment to a third party at the time of contribution after having depreciated it for several years. What is Bs holding period in Bs partnership interest?

A.	Partner B is allowed a tacked holding period for 60% of the interest attributable to the equipment contributed and may therefore treat it as having been held long term. The holding period attributable to the remaining 40% of Bs interest begins the day following Bs contribution of inventory to the partnership.
	B.	Partner B is allowed a tacked holding period for 50% of the interest attributable to Bs basis in the equipment and inventory contributed and may therefore treat it as having been held long term assuming B also held the inventory for more than one year. The holding period attributable to the remaining 50% of Bs interest begins the day following Bs contribution of the equipment and inventory to the partnership.
	C.	Partner B is allowed a tacked holding period for 30% of the interest attributable to Bs basis in the equipment contributed and may therefore treat it as having been held long term. The holding period of the remaining 70% of Bs interest attributable to the equipment (to the extent subject to Section 1245 recapture) and inventory begins the day following Bs contributions to the partnership.
	D.	Partner B assumes a long term holding period in the partnership interest assuming B has held both the equipment and inventory for more than one year prior to contributing them to the partnership.