345.4. Where a partnership disposes of property of the partnership to a person who, at the time the disposition is agreed to or otherwise arranged, is or has agreed to become a member of the partnership or to a person as a consequence of that person ceasing to be a member of the partnership,(1) the partnership is deemed to have made to the person, and the person is deemed to have received from the partnership, a supply of the property for consideration that becomes due at the time the property is disposed of equal to the total fair market value of the property (including the fair market value of the person’s interest in the property) immediately before that time; and
(2) section 286 does not apply in respect of the supply.