Sam is a calendar year individual taxpayer and is a twenty-five percent partner in the Vulcan Partnership. The Vulcan Partnership uses the fiscal year ending on June 30 for tax reporting. Sam is the managing partner of Vulcan Partnership and receives a monthly guaranteed payment from Vulcan Partnership, which deducts total guaranteed payments in arriving at the partnerships taxable ordinary income

For the partnership year ended on June 30, 2021, the partnership had total taxable ordinary income of $88,000. Sam received a guaranteed payment of $1,000 per month for the fiscal year. In addition, Sam received a distribution of $10,000 from the partnership during the fiscal year. The distribution did not exceed Sams outside tax basis.

For the partnership year ended on June 30, 2022, the partnership had total taxable ordinary income of $100,000 and Sam received a guaranteed payment of $2,000 per month for the fiscal year. In addition, Sam received a distribution of $20,000 from the partnership during the fiscal year. The distribution did not exceed Sams outside tax basis.

Research IRC Sections 706(a), 702 and 707(c). Use RIA Checkpoint for your research and prepare a tax memorandum to determine: 1. How partners are taxed when the partner is on a calendar year and the partnership is on a different fiscal tax year; 2. How guaranteed payments and distributions are taxed to partners; and 3. How much taxable income Sam must report for the calendar year ended on December 31, 2021?

Make sure your memo includes the following items:

• Summary of the facts
• List of issues identified
• List of tax laws, regulations, tax cases, etc. researched
• Analysis of tax laws as it applies to the issues identified
• Conclusions based upon your research and answers for the three questions