Consider the following example adapted from the legislative history of Internal Revenue Code Section 707(a)(2)(A):

A commercial office building constructed by a partnership is projected to generate gross income of at least $100,000 per year indefinitely. Architect, whose normal fee for architectural services is $40,000, contributes cash for a 25% interest in the partnership and receives both a 25% distributive share of net income for the life of the partnership and an allocation of $20,000 of partnership gross income for the first 2 years of partnership operations after the property is leased. The partnership expects to have sufficient cash available to distribute $20,000 to Architect in each of the first two years, and the agreement requires such a distribution.

What factors are the most important in determining whether the $20,000 allocation of gross income to Architect is a share of profits or an Internal Revenue Code Section 707(a)(2)(A) payment?