Your client, Paul, owns a one-third interest as a managing (general) partner in the service-oriented PRE LLP. He would like to retire from the limited liability partnership at the end of 2024 and asks your help in structuring the buyout transaction. He expects that his basis in the LLP interest will be about $60,000 at that time. Paul has agreed to this payment schedule, but the parties are not sure of the tax consequences of the buyout and have temporarily halted negotiations to consult with their tax advisers. Paul has retained you to determine the income tax ramifications of the buyout and to make sure he secures the most advantageous result available. tax research memo with IRAC