On March 1, 2015, Eve and Frank each contributed $30,000 cash to the newly formed EF Partnership in exchange for a 50 percent general interest. The partnership immediately borrowed $50,000 from an unrelated creditor, a debt that it does not have to repay for two years. In November, the partners estimate with reasonable certainty that EF’s 2015 operating loss will be $100,000. However, EF’s business has started to generate positive cash flow, and the partners also estimate that EF will be profitable in 2016, perhaps generating as much as $125,000 ordinary income. In anticipation of these future profits, Eve and Frank are considering withdrawing their initial cash contributions from EF before Christmas. Eve and Frank are both in the 35 percent tax bracket. What tax planning advice can you offer the partners?
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