Irene contributes land to Micro Development Partnership for a 30% interest. The land's basis is $20,000, and it has a fair market value of $80,000. Micro reports a net operating loss of $100,000 for the year. Irene devotes at least 12 hours a week to managing the partnership operations.
Identify the tax issue(s) posed by the facts presented. Determine the possible tax consequences of each issue that you identify.