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The regulations set forth four examples, two of which satisfy this incidental test and two which fail the test.

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The tax regulations define a liquidating trust as one created for the primary purpose of "liquidating and distributing its assets" (Treas.

Finally, all business trusts whose certificates of beneficial interests are publicly traded will be taxed as corporations under IRC § 7704 and are beyond the scope of this article.

The check-the-box regulations carried forward the Kintner regulations theme that ordinary trusts were classified and taxed like trusts.

Morrissey again played a central role in the early formulation of this standard by indicating that the term "associates" implies persons entering into a joint business enterprise for the purpose of sharing the gains of that business.

803 (1981), determined that a trust created with a business purpose was not a business trust because it lacked associates.

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