- A Partnership must avoid corporate characteristics - the easiest of corporate characteristics to avoid is continuity of life. Typically partnerships have a predetermined date of dissolution when they are established.
- *Most Difficult to avoid: Centralized management, no business can function without it
- *Most likely to be avoided by a DPP: continuity of life and freely transferable interests - interests cannot be freely transferred; general partner approval is required to transfer shares
An unincorporated organization with 2 or more members is generally classified as a partnership for federal tax purposes if its members engage in a trade, business, financial operation, or venture and divide its profits
A joint undertaking merely to share expenses is not a partnership (example: co-ownership of property maintained and rented or leased is nota partnership unless the co-owners provide services to the tenants)