@Accountant-Man There are enough limited partners who work and pay only SECA on their guaranteed payment portion that the IRS has put this in their LB&I campaigns to pursue these "limited partners", as defined by state law, on the basis that the carve-out in §1402(a)(13) may not apply to them under certain circumstances.  Apparently, the Big Brother has been quite successful in courts too in pursuing these limited partners in recent years.

https://www.irs.gov/businesses/corporations/lbi-active-campaigns