Contributed Assets. For purposes of paragraph (i)(5)(i) of this section, if the S corporation contributes any assets to the partnership during the recognition period and the S corporation held the assets as of the beginning of the rec- ognition period, the fair market value of the S corporation’s partnership in- terest as of the beginning of the rec- ognition period is determined as if the assets were contributed to the partner- ship before the beginning of the rec- ognition period (using the fair market value of each contributed asset as of the beginning of the recognition pe- riod). The contribution does not affect whether paragraph (i)(5)(i) of this sec- tion applies for taxable years in the recognition period before the taxable year in which the contribution was made.
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