Built in gains tracking on Marital Property Contributed to General Partnership

Question for how you tax pros would approach this: ignore it, or follow the rules?

This is the situation: a husband and wife in Texas, who owned very little separately before marriage, get married and start farming. Over time, they amass quite a bit of land and equipment. They decide it would be good to put the farming operation inside of General Partnership between them so that there is an entity to claim FSA payments and to make the business more legit in the eyes of the IRS. they both contribute land/equipment/debt 50/50 to the partnership (since it’s Texas and community property) and take a 50% interest apiece.

However, when they contribute the land and equipment, there is a wrinkle - it's encumbered by debt, and the tax basis is less than the FMV. This could lead to complicated 704c basis tracking for the partnership. However, since they are not planning on letting other members into this partnership, they never crafted a partnership agreement, and thus, there is no treatment for 704c besides the default method.

So, my question is: do I really need to track the 704(c) for built in gains since it is very unlikely for them to result in an inequity to a partner (unless they admit one - which is about as likely as pig flying)? I know the code doesn’t have an exception for this, but they are married, the contributed joint property to a GP they each have a 50% interest in, and that flows through to their joint 1040. If there ever is an audit, what’s going to change?

Anyhow, thanks for your thoughts.