...its regulations were first enacted. The Code defines a partnership to include "a syndicate, group, pool, joint venture or other unincorporated organization...which is not, within the meaning of this title, a trust or estate or a corporation." IRC§7701(a)(2). The standards necessary to determine the classification...

...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...

...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...

...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...

..."includes a syndicate, group, pool, joint venture, or other unincorporated orga39-609 0-97-2 nization, through or by means of which any business, financial...and which is not, within the meaning of this title [the Internal Revenue Code], a trust or estate or a corporation" (sec. 7701(aX2)). The statutory definition...

...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...

...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...

...Partnership The <Intemal RevenuO Code defines a partnership as including •^►"n syndicate, group, pool, joint venture, or other unincorporated organization,...which is not, within the meaning of this title, a trust or estate or a corporation ■*">" Section 7701(a)(2), see also section 761(a) This definition...

...virtually every state. Tax Issues A partnership is not considered taxable for federal income tax purposes. The term partnership includes a syndicate, group,...carried on, and which is not, within the meaning of the United States Internal Revenue Code (IRC), a corporation or a trust or estate. (IRC Sec. 761 (a).)...

...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...