Sean is admitted to the calendar year XYZ Partnership on December 1 of the current year in return for his services managing the partnership's business during the year. The partnership reports ordinary income of $100,000 for the current year without considering this transaction. Assume a nonleap year and that the partners agree to the proration method with a calendar day convention.

Requirements

a.	What are the tax consequences to Sean and the calendar year XYZ Partnership if Sean receives a 20% capital and profits interest in the partnership with a $75,000 FMV?
b.	What are the tax consequences to Sean and the XYZ Partnership if Sean receives only a 20% profits interest with no determinable FMV?