Alvin Conley has been a partner in a large accounting partnership for twenty-five years. This year, he decided to retire. Although Alvin's share of partnership capital is only \(\$ 100,000\), the partnership agreed to pay Alvin a total of \(\$ 500,000\) to liquidate his interest in the partnership. The payments will be made over ten years, \(\$ 50,000\) per year. The partnership agreement only requires the partnership to pay Alvin his \(\$ 100,000\) share of partnership capital, so the terms agreed to by Alvin and the remaining partners represent a very generous severance package. The remaining partners are comfortable with the payments, however, because Alvin brought in a large percentage of the firm's clients over the years, and thus is responsible for a large part of the firm's revenues, even after he retires. How will the payments be treated for tax purposes by both Alvin and the partnership?