How you explain to them that they would not be equal partner, Taxation

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How you explain to them that they would not be equal partner

Problem

Two people want to form an equal partnership. Mary will contribute $10,000 cash. Nora will contribute Blackacre, with a basis of $7,000, fair market value of $10,000, and subject to a 51.000 liability. Since both are contributing items with a total value of 3510.000. how would you explain to them that they would not be equal partners?

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