Hopefully you have had a tax professional review your partnership agreement tax allocation in that it meets the substantial economic effect test.
I certainly do not have many facts, but I have been doing this for quite sometime, and this just does not pass my smell test; distributions should be following income. And to have cash to distribute means that you should have been allocated income to support the distribution.
Just sayin.
*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.
