14
Handler’s. The capital accounts calculated by W&R bear this out.
Tilton was repaid his contributed capital net of capital loans in
1993, his capital loans were paid by the balance of the capital
not distributed to him, and he had no income allocated to him in
1995. Hahn had made no capital contributions to W&R which would
have had to be repaid and had no income allocated to him in 1995.
We find: (1) The withdrawing partners withdrew as members
of W&R by the end of 1994 and were no longer partners; (2) the
withdrawing partners’ partnership interests had been completely
liquidated prior to 1996; (3) the withdrawing partners had
released W&R from any further claims prior to 1996; and (4) W&R
had released the withdrawing partners from any further claims
prior to 1996. As a consequence there were no payments in 1996
by W&R to the withdrawing partners in liquidation of their
interests. Further, we find that none of the withdrawing
partners, including Handler, were partners in 1996. Because we
have found there were no payments in 1996 to the withdrawing
partners in liquidation of their interests pursuant to section
736(a)(2), we hold that no guaranteed payments to the withdrawing
partners were made.9
We have considered all of the parties’ contentions,
arguments, and requests that are not discussed herein, and we
9 Respondent has conceded that the payments of $1,000 to
Allen and $10,000 to Morse were guaranteed payments for services
rendered.
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