A son wants to Transfer Commercial  Real Estate  to his father . The property is in a Single Member  LLC.  The property has an Appraised value of $ 1.3 million. It has a mortgage on it for $ 1.6 million.  The property has a cost of $ 1,650,864 and 286,232 of Depreciation has been taken on it so its basis is $ 1,364,632. The bank is amenable to the father picking up the $ 1.6 million.  Wouldn't the son have a deemed sale and a gain of $ 1,600,000 - $ 1,364,632= $ 235,368? Wouldn't the father have a basis of $ 1,600,000 in the property? Thanks