In the "old days," one partner could contribute cash and another partner could contribute an equal value of appreciated property with no subsequent record-keeping requirements. future depreciation deductions and gains on sale of the property could be allocated to both partners equally, thereby shifting income from one taxpayer to another. a partner in a lower tax bracket (or with expiring net operating losses and the like) could report the share of the gain on sale of the asset with a relatively low corresponding tax burden. section 704(c)(1)(a) was added to the code to ensure that the partner contributing the property pays tax on any built-in gain. this prevents income shifting among taxpayers and loss of revenue to the u. s. treasury. there is no corresponding provision for s corporations—gains and losses and depreciation expense are allocated among the shareholders without regard to any built-in appreciation on contributed property. assume that a new partner or shareholder owns land valued at $100,000 in which the tax basis is $60,000. how would the "incidence of taxation" differ for the entities and owners if (1) the owner (partner or shareholder) sold the property and contributed the $100,000 proceeds versus (2) the owner (partner or shareholder) contributed that same property with the entity selling it for $100,000? what theory of partnership taxation supports this difference in treatment?