
Worthington Group has put together the following Title 26 USC IRS Codes for the benefit of client CPA's and Attorneys who who question any part of an Unincorporated Organization (Contractual Business), and its creation as a valid business entity.
It is recommended, that all of the sections we have listed from Title 26 USC be researched thoroughly, so that false or misleading information is not circulated to the prospective client who desires to preserve and protect his estate.
Worthington Group fully realizes that most CPA's and Attorneys are not cognizant of the validity of the structure of Unincorporated Organization (Contractual Business) at no fault of their own. We also are aware that this is not a reflection on any CPA or Attorney. The fact is, this information is not taught to CPA s or Attorneys, therefore they cannot be expected to know. With these facts in mind, Worthington Group makes the effort to inform and educate, thus this list of valid Title 26 USC IRS Code Sections.
| 1) Section 61 | 24) Sectioon 1.674(d)(1) |
| 2) Section 245(b) | 25) Section 861(c)(A)(B)(1)(ii) |
| 3) Section 367(a)(1)(3)(A)(iii) | 26) Section 864(b)(A)(B) |
| 4) Section 367(c)(1) | 27) Section 864(c)(1)(A)(2)(3)(4)(A)(B)(D)(i)(ii)(5)(B)(6) |
| 5) Section 367(d)(B) | 28) Section 872(b)(3)(A)(B) |
| 6) Section 643(a)(3)(6)(C) | 29) Section 2501(2) |
| 7) Section 643(g)(1)(A) | 30) Section 7701(a)(1)(2)(5)(6) |
| 8) Section 644(a)(1)(2) | 31) Section 301.7701-1(a)(1)(2)(5)(6) |
| 9) Section 645(a) | 32) Section 301.7701(30)(31) |
| 10) Section 651(a)(1)(2) | 33) Section 301.7701-4(b) |
| 11) Section 652(a)(b) | |
| 12) Section 661(a)(1) | |
| 13) Section 663(a)(1)(2)(3) There are of course other sections which relate to trust income | |
| 14) Section 667(a)(1)(2)(3)(b)(5)(c) ie: Within and Without the United States, and | |
| 15) Section 668(a) connected with a trade or business, Domestic and | |
| 16) Section 1.671-1(c) Foreign/Offshore Trusts | |
| 17) Section 1.671-2(a) | |
| 18) Section 1.671-2(b)(4) Then there are of course many Court case cites that are available | |
| 19) Section 1.672(a)-1(b)(c) which support IRS Code, Regulation and Private Letter | |
| 20) Section 1.674(a)-1(b)(3)(c) Rulings relating to 'Trusts' | |
| 21) Section 1.674(b)-1(5)(1) | |
| 22) Section 1.674(b)(8) For Offshore Trusts and International Business Corporations (IBC's) | |
| 23) Section 1.674(c)(1) many of these IRS Codes, Regulations and Private Letter Rulings apply | |
Article I Section X of the United States Constitution is the basis of the formation of the 'Unincorporated Organization' (Contractual Business) ie: 'Obligation of Contracts'
It is hoped that this information will not just be read, but will be researched and validated as to its accuracy and validity.
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