Okay. That actually makes things simpler. Those assets/cash removed from the old partnership are still treated as a return of contribution and/or capital investment to those partner's it applies to. Then at least one day after that, the assets are capital contributions to the new partnership. You can either carry the prior depreciation to the new partnership, which is what I would do. Or you can reduce the cost basis of the depreciated assets only by the amount of depreciation taken on the asset in the old partnership, (which might actually be simpler in the long run) and start depreciation all over in the new partnership, from the new and reduced cost basis. Either way avoids the recapture and taxation of prior depreciation, at this time.
Any distribution of profit from the old partnership will be taxed to the partner in the tax year that distribution is made. Doesn't matter if they put it in the new partnership or not. It's an already taxed capital contribution to the new partnership.
