The DEF LLC conducts retail men’s and women’s clothing businesses. It has the following balance sheet: 

Assets Adjusted Basis=Book Value F.M.V. 

Cash   $ 255,000                    $ 255,000 

Men’s Inventory$ 15,000      $ 90,000 

Women’s Inventory$ 90,000$ 180,000 

Blackacre$ 150,000                $ 180,000 

Whiteacre$ 135,000               $ 105,000 

Goodwill$ 0$ 45,000 $ 645,000$ 855,000 

Adjusted Basis=Book ValueF.M.V. 

Loan$120,000$120,000 D$175,000$245,000 E$175,000$245,000 F$175,000$245,000 $645,000$855,000 Blackacre and Whiteacre are nondepreciable §1231 assets; goodwill is self-created. The loan is allocated equally to the partners under §752. The partnership is planning to make a liquidating distribution to F. The basis of F’s partnership interest is $215,000 (175,000+120,000/3). The partnership makes a section 754 election. What are the tax consequences to F and the partnership if F receives $250,000 in cash in complete liquidation of his interest? Assume F is relieved of any liability on the loan.