UEI and Max Zorin are in the process of creating the View to a Kill Partnership. Zorin will contribute $500,000 cash for a 50% interest. UEI will contribute, for a 50% interest, a building ($100,000 adjusted basis; $900,000 fair market value) that is encumbered by a nonrecourse debt (that was incurred eight years ago for valid business reasons) of $400,000. The partnership will take the building subject to the debt. Bond is worried that UEI will realize a gain under these facts. Should he be worried? Why or why not? What will be UEIs initial outside basis in the View to a Kill Partnership if the transaction is completed as planned?