Sean is admitted to the calender year XYZ Partnership on December 1 of the current year in return for his services managing the partnerships business during the year. The partnership reports ordinary income of $100,000 for the current year without considering this transaction. Assume a non-leap year.

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?

What are the tax consequences to Sean and the XYZ Partnership if Sean receives only a 20% profits interest with no determinable FMV?