Rev. Rul. 66-142

In an exchange to which section 351 of the Internal Revenue Code of 1954 is applicable, the provisions of section 357(c) of the Code apply separately to each transferor so that the gain to each transferor is the excess of the sum of the amount of his liabilities assumed over the adjusted basis of all property transferred by him pursuant to the exchange determined without regard to the adjusted basis and liabilities of any other transferors.