2. Simplify Partnership was a general partnership that provided tax consulting services (and thus capital was not a material income-producing factor). Abel retired from the partnership. At the time of his retirement, the Simplify Partnership balance sheet appeared as follows:
| Asset | Adj. Basis | Book | Partner | Tax | Book | |
| Cash | $180,000 | $180,000 | Abel | $90,000 | $160,000 | |
| Acct. Rec. | -0- | $60,000 | Baker | $90,000 | $160,000 | |
| Stock | $60,000 | $120,000 | Charlie | $90,000 | $160,000 | |
| Blackacre | $30,000 | $120,000 | ||||
| Total: | $270,000 | $480,000 | $270,000 | $480,000 |
Abel received $180,000 in liquidation of his interest. The partnership agreement did not include any provision for the payment of goodwill. A § 754 election has been made. What are the tax consequences to Abel and to Simplify?