| United States. Court of Claims, Audrey Bernhardt - 1962 - 964 lapas
...characteristics is to be treated for tax purposes as a trust or as an association depends on whether there are associates and an objective to carry on business and divide the gains therefrom. On the other hand, since associates and an objective to carry on business and divide the gains therefrom... | |
| United States. Internal Revenue Service - 1962 - 786 lapas
...against the organization. Neither you nor any other member may transfer membership. The organization has associates and an objective to carry on business and divide the gains therefrom. However, the organization does not have the corporate characteristics of limited liability, free transferability... | |
| 1989 - 596 lapas
...whether there are associates and an objective to carry on business and divide the gains therefrom. On the other hand, since associates and an objective...partnerships, the determination of whether an organization which has such characteristics is to be treated for tax purposes as a partnership or as an association... | |
| 1970 - 360 lapas
...whether there are associates and an objective to carry on business and divide the gains therefrom. On the other hand, since associates and an objective...partnerships, the determination of whether an organization which has such characteristics is to be treated for tax purposes as a partnership or as an association... | |
| 1992 - 616 lapas
...characteristics is to be treated for tax purposes as a trust or as an association depends on whether there are associates and an objective to carry on business and divide the gains thereirom. On the other hand, since associates and an objective to carry on business and divide the... | |
| United States. Congress. Senate. Committee on Government Operations - 1969 - 1640 lapas
...characteristics of a corporation • • " are common to partnerships and corporations. • • • since associates and an objective to carry on business...partnerships, the determination of whether an organization which has such characteristics Is to be treated (or tax purposes as a partnership or as an association... | |
| United States. Tax Court - 1967 - 1032 lapas
...profit, as discussed above), (3) continuity of life, and (4) free transferability of interests. Having "associates" and an "objective to carry on business and divide the gains therefrom" are common to both corporations and partnerships and should not be considered. Sec. 301.7701-2, Proced.... | |
| United States. Internal Revenue Service - 1978 - 630 lapas
...to be treated for federal tax purposes as a trust or as an association depends on whether there are associates and an objective to carry on business and divide the gains therefrom. In Wyman Building Trust v. Commissioner, 45 BTA 155 (1941), acq., 1941-2 CB 14, the United States Board... | |
| United States. Internal Revenue Service - 1978 - 636 lapas
...characteristics is to be treated for tax purposes as a trust or as an association depends on whether there are associates and an objective to carry on business and divide the gains therefrom. Section 301.7701-4(b) of the regulations states, in part, that there are other arrangements that are... | |
| United States. Tax Court - 1981 - 1236 lapas
...characteristics is to be treated for tax purposes as a trust or as an association depends on whether there are associates and an objective to carry on business and divide the gains therefrom. * * * [Sec. 301.7701-2(aX2), Proced. & Admin. Regs.] Accordingly, our analysis will focus primarily... | |
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