Bert and Jos plan to combine their unincorporated businesses by forming a partnership. Bert has substantially appreciated

Bert and José plan to combine their unincorporated businesses by forming a partnership. Bert has substantially appreciated business assets. Moreover, if he transfers all the business’ liabilities and assets, the liabilities will exceed the adjusted basis of the assets but not their FMV. José will render services to the entity in addition to transferring his business assets. What tax issues should Bert and José consider?