TRANSACTIONS BETWEEN A PARTNER AND THE …

Allocations of gross partnership income do not share this element of entrepreneurial risk and therefore are more liable to challenge under Code Section 707(a)(2)(A). Indeed, from this perspective the effect of Code Section 707(a)(2)(A) is to identify those allocations and distributions that together constitute disguised guaranteed payments.

  Transactions, Between, Partner, Allocation, Partnership, Transactions between a partner and the