THATCHER ROY D.THATCHER LEROY. PAUL & YOUNG LAWYERS FIRST BvYOUNG SECURITY BANK OGDEN, UTAH THATCHER December J. Me. & M. S, Ogden, Utah Browning 4, BUILDING 1936 Company Gentlemen: The Commissioner of Internal Revenue has recently issued Regulations 94, with respect to income tax under the Revenue Act of 1936. Article 1001-2 is as follows: "Art. 1001-2. Association.-- The term "associa-— tion" is not used in the Act in any narrow or technical sense. It includes any organization, created for the transaction of designated affairs, or the attainment of some object, which, like a corporation, continues notwithstanding that its members or participants change, and the affairs of which, like corporate affairs, are conducted by a Single individual, other It is group, acting in a immaterial whether ated by an a committee, agreement, a board, or some representative capacity. such organization is cre- a declaration of trust, a statute, or otherwise. It includes a voluntary assoclation, a joint-stock association or company, a "business" trust, a "Massachusetts" trust, law" trust, an "investment" trust (whether a “common of the fixed or the management type), an interinsurance exchange operating through an attorney in fact, a part— nership association, and any other type of organiza-— tion (by whatever name known) which is not, within the meaning of the Act, a trust or an estate, or a partnership. if the conduct of the affairs of a corporation continues after the expniration of its charter, or the termination of its existence, it becomes an association". I believe that regulation correctly states the law. Articles three and nine of the Olsen trust, it seems to me, give the trustees power to engage in any kind of business they may desire to engage in with the trust estate. | Article sixteen provides that "changes in beneficiary from any cause shall be duly noted by the trustees, who shall