I believe this validates your point. From the pmarca(Mark Andreesen) blog post "The truth about VC, part 2" How to Make a Venture Capitalists Head Explode: P

I believe this validates your point. From the pmarca(Mark Andreesen) blog post "The truth about VC, part 2" How to Make a Venture Capitalists Head Explode: Point out to her that her compensation from carried interest should be taxed as ordinary income, not capital gains, since she's receiving a fee for service and it's not her capital at risk.