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" partnership" includes a syndicate, group, pool, joint venture, or other unincorporated organization, through or by means of -which any business, financial operation, or venture is carried on, and which is not, within the meaning of this Act, a trust or... "
Regulations 86 Relating to the Income Tax Under the Revenue Act of 1934 - Page 370
by United States. Bureau of Internal Revenue, United States. Internal Revenue Service - 1935 - 466 pages
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Federal Taxation of Real Estate

Allan J. Samansky, James Charles Smith - 1985 - 840 pages
...What Is a Partnership? [a] — Introduction. The Code defines a partnership as "a syndicate, group, pool, joint venture, or other unincorporated organization...operation, or venture is carried on, and which is not... a corporation or a trust or estate."33 The use by the parties of a particular label to describe their...
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Reports of the Tax Court of the United States, Volume 89

United States. Tax Court - 1988 - 1406 pages
...the other investors. Respondent's regulations state the term "partnership" for Federal tax purposes "includes a syndicate, group, pool, joint venture,...business, financial operation, or venture is carried on." Sec. 1.761-l(a), Income Tax Regs. Respondent's regulations also state: Mere co-ownership of property...
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Limited Liability Companies: Formation, Operation, and Conversion

Robert W. Wood - 2001 - 284 pages
...IRS in a letter.129'1 [A] Statutory Definition of Partnership Section 761 (a) provides generally that the term "partnership" includes a syndicate, group,...operation, or venture is carried on, and which is not a corporation or a trust or an estate. It is noteworthy that the Code does not clearly require a joint...
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Report of Investigation of Enron Corporation and Related Entities Regarding ...

2003 - 966 pages
...federal income tax purposes. Classification of the Company Section 7701(a)(2) of the Code provides that the term "partnership" includes a syndicate, group,...operation, or venture is carried on, and which is not a trust or estate or a corporation. Section 301. 7701 -1(b) of the Treasury Regulations states that...
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Construction Accounting Deskbook, 2005

Louis P Miramontes, L Rice Hugh - 2004 - 1408 pages
...may, under appropriate circumstances, be treated as partnerships for tax purposes. The enumeration includes "a syndicate, group, pool, joint venture,...operation, or venture is carried on? and which is not ... a trust or estate or a corporation." Generally, a state law partnership or any other entity not...
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Pension and Employee Benefits: Preambles to final and temporary regulations

United States - 2004 - 1772 pages
...of Provisions Section 7701 (a) (2) of the Code defines a partnership to include a syndicate, group, pool, joint venture, or other unincorporated organization,...financial operation, or venture is carried on, and that is not a trust or estate or a corporation. Section 7701 (a) (3) defines a corporation to include...
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The Tax Law of Associations

Bruce R. Hopkins - 2006 - 384 pages
...partnership. The term partnership is defined in the federal tax law to include a "syndicate, group, pool, joint venture, or other unincorporated organization,...operation, or venture is carried on, and which is not ... a trust or estate or a corporation."2 This term is broadly applied. For example, co-owners of income-producing...
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Joint Ventures Involving Tax-Exempt Organizations

Michael I. Sanders - 2007 - 955 pages
...a discussion of PRIs. 100 See Chapter 11. See Sections 9.1, 11.5. 102 See Section 9.7. purposes.103 The term partnership includes a syndicate, group,...operation, or venture is carried on, and which is not a trust or estate or a corporation.104 If a partnership is treated for federal income tax purposes...
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Guidebook to Illinois Taxes (2008)

Fred Conklin - 2007 - 472 pages
...partnership may claim the credit for personal property tax replacement income tax, discussed at 1 1201. A "partnership" includes a syndicate, group, pool, joint...operation, or venture is carried on, and which is not a trust, estate, or corporation. "Partner" includes a member in a syndicate, group, pool, joint venture,...
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Guide to Limited Liability Companies

Tom Cody, Dem A. Hopkins, Lawrence A. Perlman, Linda L. Kalteux - 2007 - 388 pages
...others. For federal tax purposes, the Internal Revenue Code defines a partnership as a syndicate, group, pool, joint venture, or other unincorporated organization...operation, or venture is carried on and which is not ... a corporation or a trust or estate.2 A general partnership, like a sole proprietorship, is not...
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