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87 . Phil Justin and Mark IVone are equal partners in the Justin I've partnership . OnDecember 15, 2015, Phil Justin transferred land with a fair market value of $100 , 000to the Justin Tyme partnership . Phil had a basis in the land of $ 70, 000 . On June 1 ,2016 , Phil withdrew cash of $50,000 from the Justin Ivine partnership . An IRS agentis currently reviewing Phil's 2015 and 2016 income tax returns .a .Phil should not be concerned because the contribution was a nontaxable eventunder section 7 21 and the distribution is tax free since he has sufficient basis inthe partnership .D.The IRS agent will likely assert that the transaction was a disguised sale andthat Phil should have reported $15, 000 gain on the sale .[ .The IRS agent will be unable to assert the transaction was a disguised sale since*the transfer of the land and the distribution of the cash were in different years .d .The IRS agent will be unable to assert the transaction was a disguised sale sincethese rules do not apply to a partnership and a 50 percent or more partner .