Nora transfers real property with a basis of $2,000,000 and a fair market value of $10,000,000 to an existing partnership for an interest therein. Shortly thereafter, the partnership distributes $3,000,000 to Nora. Describe the tax consequences to Nora. Would your answer differ if the distribution to Nora occurred three years after the contribution? Does it matter if Nora incurred $1,000,000 in capital improvements to the contributed property within 2 years of the contribution?