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 As holding period in As partnership interest?

A.	Partner A is allowed a tacked holding period for 50% the interest attributable to the fair market value of land contributed and may therefore treat it as having been held long-term. The holding period attributable to the remaining 50% of As interest begins the day following As contribution of money to the partnership.
	B.	Partner A is allowed a tacked holding period for 40% the interest attributable to As basis in the land contributed and may therefore treat it as having been held long-term. The holding period attributable to the remaining 60% of As interest begins the day following As contribution of both money and land with a net unrealized gain to the partnership.
	C.	Partner As holding period in the partnership interest begins the day after A contributes the money and land to the partnership.
	D.	Partner A assumes a long term holding period in the partnership interest attributable to the contributed land because contributions of money are disregarded for this purpose.