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D is corrent. The requirement is to determine the amount of the partnership’s capital gain from the sale of securities to be allocated to Gregory. Since the securities were sold for more than their fair market value on the date of contribution, the entire precontribution gain of $24,000 ($75,000 - $51,000) would be allocated to Gregory. In addition, Gregory would be allocated 1/3 of the postcontribution gain from the securities, which is $1,000 [($78,000 - $75,000) x 1/3]. Gregory should therefore be allocated $25,000 ($24,000 + $1,000) of the partnership’s capital gain.
A is incorrect. Gregory is taxed on the precontribution appreciation plus 1/3 of the additional $3,000. 
B is incorrect. Gregory is taxed on the precontribution appreciation plus 1/3 of the additional $3,000. 
B is incorrect. Gregory is taxed on the precontribution appreciation plus 1/3 of the additional $3,000.