PROBLEMS 2 + 3 ONLY 
into account any guaranteel pl and the profits are $20,000, consisting of $12,000 of ord income and $8,000 of long-term capital gain (d) How would the results in (o), above, change under Prop. Re 2. G, a cash method taxpayer, is a one-third partner in the FGH a method partnership. G is employed by the partnership and is entitled guaranteed payment of $10,000 for year one. G's outside basis during one is zero. G's agreement with the partnership specifi the $10,000 guaranteed payment on June 1 of year three. On January 1 o year two, the partnership sells an asset (basis $15,000, fair market value $15,000) and distributes $5,000 cash to each partner. What result to G? g 1.707-1(c) Ex. 2? accrual es that he will receive 8. In a situation similar to that in Revenue Ruling 69-180, supra p. 227 is it possible for amounts paid to a partner in excess of the guaranteed payment to be classified as a Section 707(a)(1) payment? 4. Partner renders services worth $10,000 to Partnership in which he isa partner. Without regard to Partner's services, Partnership has $75,000 ordinary income and $25,000 of long-term capital gain for the year. Both Partner and Partnership are calendar year taxpayers, but Partner uses cash method of accounting and Partnership uses the accrual metuio not make a payment to Partner during the year permitted it accrues the expense, which is currently deductible un 162. Determine the tax consequences of the following alte transactions to Partner and Partnership: , but where der Section ternative (a) In recognition of his so into account any guaranteel pl and the profits are $20,000, consisting of $12,000 of ord income and $8,000 of long-term capital gain (d) How would the results in (o), above, change under Prop. Re 2. G, a cash method taxpayer, is a one-third partner in the FGH a method partnership. G is employed by the partnership and is entitled guaranteed payment of $10,000 for year one. G's outside basis during one is zero. G's agreement with the partnership specifi the $10,000 guaranteed payment on June 1 of year three. On January 1 o year two, the partnership sells an asset (basis $15,000, fair market value $15,000) and distributes $5,000 cash to each partner. What result to G? g 1.707-1(c) Ex. 2? accrual es that he will receive 8. In a situation similar to that in Revenue Ruling 69-180, supra p. 227 is it possible for amounts paid to a partner in excess of the guaranteed payment to be classified as a Section 707(a)(1) payment? 4. Partner renders services worth $10,000 to Partnership in which he isa partner. Without regard to Partner's services, Partnership has $75,000 ordinary income and $25,000 of long-term capital gain for the year. Both Partner and Partnership are calendar year taxpayers, but Partner uses cash method of accounting and Partnership uses the accrual metuio not make a payment to Partner during the year permitted it accrues the expense, which is currently deductible un 162. Determine the tax consequences of the following alte transactions to Partner and Partnership: , but where der Section ternative (a) In recognition of his so
