Marvin Bridges is a 25 percent partner in the Munson partnership. On November 23, 2017, Marvin contributes property with an adjusted basis of \(\$ 75,000\) and a fair market value of \(\$ 250,000\) to the Munson partnership. On March 15, 2018, Marvin receives a \(\$ 187,500\) cash distribution from the partnership.

a. Why would the IRS seek to classify the transactions as a disguised sale?

b. Assume that the IRS is successful in classifying the transactions as a disguised sale. Outline the income tax consequences to Marvin.