Question 1: Darryl, Darrell, and David form a 1/3d-1/3d-1/3d partnership. Darryl contributes land worth $100,000 with a basis of $100,000. Darrell contributes supplies worth $100,000 with a basis $90,000. David receives his 1/3d interest for his services in putting the deal together and for the future services. Thus if the partnership were to liquidate, David would get 1/3d of the partnership's assets. Does the deal make sense? How is the partnership formation taxed? (Note that Section 709 requires 60-month amortization for costs incurred in organizing a partnership, analogously to Section 248's rule for corporations, and disallows any deduction - ever - for costs of selling interest in a partnership).
Question 2: What if David gets only 1/3d of future profits, which are speculative but gets no interest in the partnership's existing assets?
Question 3: What if David gets only 1/3d of future profits, but Darryl and Darrell also contributed high quality corporate bonds to the partnership?