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Total FMV
$1,350,000
Total Basis
$380,000
Total Built-In Gain
$970,000
§ 704(c) Properties
2 of 2
Contributed Assets
Asset Name
Type
FMV ($)
Adj. Basis ($)
Built-In Gain
Status
$820,000
§ 704(c)
$150,000
§ 704(c)
Basis Outputs
Contributor's outside basis (§ 722)
$380,000
Partnership's inside basis (§ 723)
$380,000
Book-tax disparity (built-in gain)
$970,000
§ 704(c) tracking required
2 of 2 assets
§ 721(a) defers — does not eliminate — the $970,000 built-in gain
It will be allocated back to the contributor under § 704(c) when the partnership sells or depreciates the property.
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