Guaranteed Payments Made In Kind By A Partnership

If a partnership makes payment to partner for services rendered in the latter's capacity as or use of capital, extent that is determined without regard income, it characterized by Internal Revenue Code "guaranteed payment" and treated differently from other distributions. In addition, if liquidation retiring deceased partner's interest partnership, part may be guaranteed section 736(a)(2). We will discuss Part VI this article circumstances when liquidating payment." While 707(c) 736(a) refer "payment," there no reason must made cash, leading treatises on taxation agree payments can kind.As used article, "liquidating" distribution refers pursuant partnership. All distributions are sometimes referred "operating" payments.