Accounting/Tax question (MLPs)

When a private owner of a public MLP sells a big block of shares to the public, where does incremental non-cash amortization come from?

For example, private holder sells their 10% stake in the MLP and as a result the public shareholders see an additional $1.0B of non-cash amortization over the next 15 years to deduct from taxable income. NPV of that additional tax shield is word $1.0 per public share. I get the back end, but where does that $1.0B come from?

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