In which of the following independent situations would the transaction most likely be characterized as a disguised sale?
- Tom contributes appreciated property to the BBC Partnership. Thirty months later, he receives a distribution from the partnership of $15,000 cash. None of the other partners received a distribution. There was no agreement that BBC would make the distribution, and Tom would have made the contribution whether or not the partnership made the distribution.
- Partner Matt contributes appreciated property to the equally-owned four-member STSS Partnership in exchange for a 25% interest. After 20 months, the STSS Partnership distributes $10,000 to partners Aliza, Nicole, and Maura, and $50,000 to Matt.
- Beth contributes property with a basis of $20,000 and a fair market value of $50,000 to the LCB Partnership in exchange for a 20% interest therein. The partnership agrees to distribute $20,000 to Beth in 15 months if partnership cash flows from operations exceed $100,000 at that time. The partnership does not expect to produce operating cash flows of over $100,000 for at least five years.
- Partner Bill contributes appreciated property to the PAS Partnership, and three years later PAS distributes $100,000 proportionately to the partners.