Your question and facts require a one on one with a tax professional.
Too many questions and the need for additional facts for a forum such as this to be able to respond.
You have Section 704(b) issues that need to be addressed, which based on your initial facts, are very complicated; end result is that the allocation must meet the substantial economic effect regulations.
What you want to do is really more along the lines of providing a guaranteed payment to Alex for the financial component of the transaction.
Seek a tax professional that is extremely strong in the partnership allocation area.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
