On January 18, Mr. X contributes a machine with an adjusted tax basis of $89,000 and a fair value of $90,000 for a 10% interest in Yellow Dog Limited Partnership; For a 45% interest in Yellow Dog, Ms. Y contributes a building with an adjusted tax basis of $380,000 and a fair value of $450,000 along with the land the building sit on. The land had an adjusted tax basis of $80,000 and a fair value of $120,000. Finally, Ms. Z contributes $200,000 cash for a 10% interest in Yellow Dog. There was no written plan of organization. Since control is not established immediately after the transfers, will X, Y and Z have to recognize gain?

a. Yes, all three will recognize gain.

b. X and Y will have to recognize gain but Z will not

c. X and Z will have to recognize gain but Y will not

d. None of the above