On July 1, 2015, Stu contributes Land with a FMV of $50,000 and an adjusted tax basis of $10,000 to a General Partnership in exchange for a 20% interest therein. The other 80% partners contribute cash. On January 1, 2016, the partnership distributes $50,000 in cash to Stu. His interest is not terminated, and you should assume the partnership had no liabilities on that date.

List two Subchapter K "regimes" under which gain would likely result to Stu upon the distribution on 1-1-16 (either references to Code Sections or general descriptions of the taxation regime are fine).