Partnership distribution

PLEASE cite to source law (codes, regulations, relevant cases etc.) do not make jumps in logic, show all steps! Do not stop analysis because one element fails, if applicable test requires elements.

Elias contributed $100,000 to become a 1/3 partner in CDE Partnership. The partnership agreement specifies that Elias’s 1/3 share of partnership profits is calculated before deducting any guaranteed payments, and guarantees that his share of “profits” will never be less than $20,000. Additionally, the partnership agreement specifies that Elias will receive an annual 6% “interest payment” on his capital contribution.

What is Elias’s distributive share and guaranteed payment (if any) if the partnership earns $45,000 of ordinary income and $25,000 of long-term capital gains for the year?


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