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April 23, 1960


JAMA. 1960;172(17):1941-1944. doi:10.1001/jama.1960.03020170067018

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PROPOSED INTERNAL REVENUE REGULATIONS CONCERNING PHYSICIANS IN GROUP PRACTICE  January 21,1960Honorable Dana Latham Commissioner of Internal Revenue Internal Revenue Service Washington 25, D. C.Dear Sir:In connection with proposed Regulations, Sections 301.7701-1, 2, and 3, the American Medical Association desires the opportunity to have its representatives testify orally at the public hearing and submits herewith, in addition, certain comments and suggestions.We are concerned that the regulations in the form in which they were published in the Federal Register on December 23, 1959, are not likely to attain the desired objective of clarifying, for tax purposes, the distinctions between associations and partnerships.Section 301.7701-1 (c) states that local law shall govern "in determining whether the legal relationships which have been established in the formation of an organization are such that the standards are met." State laws pertaining to associations and partnerships not only differ greatly, but in many

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