...property of the required character, the basis of such ll.t | fl.< Illl •..(1C »«•• IVI,.., \ pool, joint venture, or other unincorporated organization...which Is not, within the meaning of this title, a corporation or a trust or estate. Under regulations the Secretary or his delegate may, at the election...

...(2). §411(d) defines "partnership" and "partner" as found in 26 USC §761(a) and (b), respecitvely. A "partnership" includes a syndicate, group, pool joint...which is not, within the meaning of this title, a corporation or a trust or estate. A "partner" is a "member of a partnership." The issue presented herein...

...mean and include an individual, a trust, estate, partnership, association, company or corporation. (2) Partnership and partner. The term "partnership"...which any business, financial operation, or venture la carried on, and which is not, within the meaning of this title, a trust or estate or a corporation;...

...its regulations were first enacted. The Code defines a partnership to include "a syndicate, group, pool, joint venture or other unincorporated organization...of this title, a trust or estate or a corporation." IRC§7701(a)(2). The standards necessary to determine the classification of an unincorporated association...

...to "The Bluebird." Section 761(a)24 defines a "partnership" broadly to include "a syndicate, group, pool, joint venture or other unincorporated organization...and which is not, within the meaning of this title [subtitle], a corporation or a trust or estate." The meaning of the term for Federal tax purposes is...

...relate to partnerships and corporations. The statutory definition of a partnership provides that it "includes a syndicate, group, pool, joint venture,...of this title, a trust or estate or a corporation" (sec. 7701(a)(2)). The statutory definition of a corporation provides that it "includes associations,...

...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...

...Partnership The <Intemal RevenuO Code defines a partnership as including •^►"n syndicate, group, pool, joint venture, or other unincorporated organization,...of this title, a trust or estate or a corporation ■*">" Section 7701(a)(2), see also section 761(a) This definition subsumes two issues: (1) whether...

...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...

...construed to mean and include an individual, a trust, estate, partnership, company, or corporation. (2) PARTNERSHIP AND PARTNER. — The term "partnership"...syndicate, group, pool, joint venture, or organization. (3) CORPORATION. — The term "corporation" includes associations, joint-stock companies, and insurance...