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George received a fully vested 10% interest in partnership capital and a 20% interest in future partnership profits in exchange for services rendered to the

George received a fully vested 10% interest in partnership capital and a 20% interest in future partnership profits in exchange for services rendered to the GHP, partnership. The future profits of the partnership are subject to normal operating risks.

a. Will George be taxed currently on receipt of the capital interest? If so, how will the amount be determined?

b. Will George be taxed currently on receipt of the profits interest? If so, how will the amount be calculated?

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