id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-407	Kahn, Douglas A.	Is the Report of Lazarus's Death Premature? A Reply yo Cameron and Postlewaite	2022	41	.pdf	application/pdf	19504	870	53	Unless the partnership agreement excludes from the calculation of the partner’s share of partnership income gain or loss that is recognized by making a guaranteed payment in kind, the gain recognized by the partnership on the guaranteed payment portion of the distribution will increase the partnership’s income, thereby increasing the dollar amount of the distributee partner’s share of partnership income and accordingly increasing the percentage of the distributed property that constitutes an ordinary section 731 distribution. Proposal of standards for determining partner capacity contained in the legislative history – Section 707(a)(2) is aimed at preventing a partnership from successfully disguising a payment to a partner for the purchase of property or for services as an allocation of partnership income.	cache/ftr-407.pdf	txt/ftr-407.txt