December 5,1956. Mr. dos. E. Olsen, 510 Galer Place, Glendale, California. Dear <2oe: from Mr. Referring to your recent is following the letter, Thatcher: tthe Commissioner issued Regulations the Hevenue Act of tart. is not 1001-2. used of Internal Revenue Association -- has recently 94, with respect to income tax under Article 1001-2 is as follows: 1936. the in in Act includes sense. it includes a voluntary any any The term "association" narrow or techhical the for created organization, transaction of designated affairs, or the attainment continues of some object, which, like a corporation, participants or members its that notwithstanding change, and the affairs of which, like corporate affairs,are conducted by a single individual, a committee, a board, or some other group, acting in it is immaterial whether a representative capacity. by an agreement, 4 created is such organization It or otherwise, statute, a declaration of trust, agsociation or attorney in fact, a joint-stock a association, company, trust, “business” 4 "Massachusetts" trust, a "common law" trust, an "investment" trust (whether of the fixed or the management type), an interinsurance exchange operating through an other type of association, a partnership organization (by whatever name any and which known) is not, within the meaning of the Act, a trust or an If the conduct of the affairs estate, or a partnership. of a corporation continues after the expiration of its it becharter, or the termination of its existence, comes an association". I believe that tegulation 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 any cause shall be duly noted by the correct their register accordingly”. in beneficiary trustees, who from shall Article seventeen permits the trustees to make partial distributions from time to time and a final distribution when the estate is closed, but all distributions are to be made to beneficiaries of record.