The LLC at issue serves as the investment manager for a managed fund which is a family of investment partnerships. The LLC has full authority and responsibility to manage and control fund business and affairs, and is primarily responsible for conducting market research and trading activity of the fund. The LLC receives management fees for its work. The LLC treated all partners/members as limited partners such that their distributive shares were not subject to self-employment tax. Only guaranteed payments were subject to self-employment tax. The IRS determined that I.R.C. Sec. 1402(13) only excluded from self-employment tax the income distributed to partners/members that were mere investors and did not actively participate in the partnership's/LLC's business operations. The IRS determined that the present situation was analogous to the facts of Renkemeyer, Campbell, and Weaver LLP v. Comr., 136 T.C. 137 (2011), and the earnings of each partner/member were a direct result of the services rendered on behalf of the LLC by the partners/members. The payments were also not "wages" and the reasonable compensation rules of corporations are inapplicable. CCM 201436049 (May 20, 2014).