id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-406	Cameron, David L.; Postlewaite, Philip F.	The Lazarus Effect: A Commentary on I-Kind Guaranteed Paymentss	2022	72	.pdf	application/pdf	34741	1398	51	Instead, they largely limit any discussion of § 707(a)(2) to the issue of distinguishing payments under § 707(a)(1) from a partner’s distributive share of partnership income and a distribution of partnership property and continue to cite the law as it existed prior to 1984, including the Pratt decision, when considering the capacity question in the context of guaranteed payments. They then move their focus from the typical43 type of guaranteed payment (a payment fixed in amount) to address an infrequent, atypical type of guaranteed payment (a payment structured as a percentage of partnership income with a minimum dollar amount) and the tax issues which present themselves in such a case.44 2006]	cache/ftr-406.pdf	txt/ftr-406.txt