Jason and Daniel are forming the JD Partnership. Jason contributes $300,000 cash, and Daniel contributes nondepreciable property (adjusted basis of $80,000 and a fair market value of $330,000). The property is subject to a $30,000 liability, which is also transferred into the partnership, and is shared equally by the partners for basis purposes. Jason and Daniel share in all partnership profits equally except for any precontribution gain, which must be allocated according to the statutory rules for built-in gain allocations.
(I) What is Daniel's adjusted tax basis for his partnership interest immediately after the partnership is formed?
(II) What is the partnership's adjusted basis for the property contributed by Daniel?
(III) If the partnership sells the property contributed by Daniel for $360,000, how is the tax gain allocated between the partners?