Steve Seller owns raw land he holds for investment located near Fresno, California. Steve has owned the land for 9 months.

Relevant information regarding the property is as follows:

Land:

Fair Market Value: $10 MM

Adjusted Basis: $6 MM

Debt: None.

On January 1, 20x1 Steve sold the land to Bonnie for $10 MM sales price pursuant to the following terms:

1) $2 MM cash payment to Steve; and

2) $8 MM nonrecourse note payable by Bonnie to Steve as follows:

(a) interest rate--accrued and payable at the applicable federal rate.

(b) principal payments due on January 1 of each year, as follows:

--January 1, 20x2: $2 MM

--January 1, 20x3: $4 MM

--January 1, 20x4: $2 MM.

What is Bonnie's cost basis in the land ?