In Rev. Rul. 81-301, which of the following is not a factor considered by the IRS in determining whether a partner receives payments in her capacity as a partner, or is instead acting as a third party?
a. The partner’s services are supervised by the partnership’s directors.
b. Payments to the partner are based on one or more items of partnership income.
c. The adviser also provided similar investment management services to others as part of its regular trade or business.
d. The other partners could terminate the service agreement.