Rajesh Contributed Appreciated Property to the RS Partnership in Year

Multiple Choice

Rajesh contributed appreciated property to the RS Partnership in year 1. In year 4, that property was distributed to Simon. Which one of the following statements best captures the tax consequences of the distribution?

A) Distributions are tax-deferred transactions; because no cash is distributed, neither the partners nor the partnership recognize gain on the distribution.
B) The partnership recognizes the precontribution gain; Simon's basis in the property is increased by the amount of recognized gain.
C) Simon recognizes the precontribution gain and increases his basis in the partnership interest; the partnership's basis in other property is increased by the amount of recognized gain.
D) Rajesh recognizes the precontribution gain and increases his basis in the partnership interest; Simon's basis in the distributed property is increased by the amount of recognized gain.
E) Rajesh recognizes the precontribution gain and increases his basis in the partnership interest; the partnership's basis in other property is increased by the amount of recognized gain.