Miguel Contributed Substantially Appreciated Property to the MR Partnership in Year

Multiple Choice

Miguel contributed substantially appreciated property to the MR Partnership in year 1. In year 4, other property was distributed to Miguel. Which one of the following statements is most likely to be true regarding the contribution and/or distribution?

A) Miguel recognizes precontribution gain in year 4 when the second property is distributed to him.
B) Miguel recognizes the precontribution gain on an amended tax return for year 1 when the second property is distributed to him.
C) The partnership recognizes the precontribution gain in year 4 and allocates that gain to all the partners.
D) The partnership recognizes the precontribution gain in year 1 and allocates that gain to Miguel.
E) Partnership contributions and distributions are tax-deferred transactions; when no cash is involved, no gain or loss is recognized.