Ina bona fide, arm’s-length transaction, a son, age 42, purchased from his father a 40 percent interest in the father's partnership, paying the full fair market value. The partnership is a manufacturing concern. The partnership's ordinary income, before partners’ salaries, was

$100,000. The father and son were allocated guaranteed payments of $60,000 and $40,000, respectively. The salary paid to the father is reasonably equivalent to comparable services performed for similar companies. The son rendered no services to the partnership. What will be the likely approach of the IRS on such payments?