Noah, Sadie, and Maven form a LLC using tax partnership for tax filing purposes. Noah contributes $1 Million cash for a 1/3 interest in capital and profits. Sadie does the same. Maven contributes a patent with $1.3 million FMV with a $300,000 loan. The LLC takes over the loan. Maven also has a 1/3 interest in capital and profits. Maven has $600,000 tax cost (basis) in the patent.