Capital gains on asset contribution to partnership: market-value credit to capital account triggers taxable capital gains inclusion. When an individual brings a capital asset into a partnership and his exclusive rights in the asset are extinguished, that contribution is a transfer under sec.2(47); crediting the asset's market value to the partner's capital account constitutes consideration. Consequently, any profits or gains arising from the transaction are chargeable as capital gains and should be included in the partner's income for assessment.