Andrew Contributes Property with a Fair Market Value of $6,000,000

Andrew contributes property with a fair market value of $6,000,000 and an adjusted basis of $2,000,000 to AP Partnership.Andrew shares in $3,000,000 of partnership debt under the liability sharing rules,giving him an initial adjusted basis for his partnership interest of $5,000,000.One month after the contribution,Andrew receives a cash distribution from the partnership of $3,000,000.Andrew would not have contributed the property if the partnership had not contractually obligated itself to make the distribution.Assume Andrew's share of partnership liabilities will not change as a result of this distribution.