Tom is a 55% general partner in the RST Partnership. Tom wants to retire, and the other two partners, Stacy and Rich, want to continue the partnership business. They agree that the partnership will liquidate Tom's interest in the partnership by paying him 20% of partnership profits for each of the next ten years. Explain why Sec. 736 does (or does not) apply to the partnership's payments to Tom.

Answer in 75 words or more.