in x1, adam and jason formed abc, llc, a car dealership in kansas city. in x2, adam and jason realized they needed an advertising expert to assist in their business. thus, the two members offered cory, a marketing expert, a 1/3 capital interest in their partnership for contributing his expert services. cory agreed to this arrangement and received his capital interest in x2. if the value of the llc's capital equals $180,000 when cory receives his 1/3 capital interest, which of the following tax consequences does not occur in x2?