Daniel has no family to inherit his 80% capital and profits interest in the CD Partnership. To ensure the continuation of the business, he gives a 20% capital and profits interest in the Partnership to David, his best friend's son, on the condition that David work in the partnership for at least five years. David receives guaranteed payments for his work. Daniel takes no salary from the partnership, but he devotes all his time to the partnership's business operations. What tax issues should Daniel and David consider with respect to the gift of the partnership interest and Daniel's employment arrangement with the partnership?