I would differ with your statement. I have numerous
partnerships that involve contributed property. Typically a
partner that contributes property other than cash has a
capital account that is credited with the value of that
property, not the tax basis. If A and B form a partnership
with A contributing land with basis of $100 and value of
$1,000 and B contributing cash of $1,000, they will each be
credited with $1,000 in their capital account. While A's
capital account would be $1,000 his basis is only $100.
True, but he did not ask about the capital account BALANCE,
he asked about its tax basis, and as you pointed out these
are not the same. The tax basis to the partnership of a
tax-deferred contribution of a capital asset is the same as
the partner's basis before contribution (§723). The partner
gets a substituted basis in his/her partnership interest. At
this point we have two assets, the property in the hands of
the partnership and the partner's interest in the
partnership. Both have the same basis (inside and outside
basis). If the partner sells the partnership interest, the
inside basis of the contributed property does not change,
but the buyer's basis in the partnership interest is what
was paid. At this point the inside and outside basis is
different.