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Under Section 761 (a) of Subchapter K of the Internal Revenue Code (IRC) of 1954, certain unincorporated organizations may be excluded, completely or partially, from treatment as partnerships for federal income tax purposes This exclusion applies only to those organizations used (1) for investment purposes rather than as the active conduct of a business, or (2) for the joint extraction, production, or use of property, but not for the purpose of selling the products or services extracted or produced The use of limited partnerships because of favorable tax considerations has been signi cantly reduced as a result of the Tax Reform Act of 1986 Prior to passage of that Act, limited partnerships as a form of tax-sheltered investment had been used in real estate, motion picture production, oil drilling, cable TV, cattle feeding, and research and development The limited partnership gave investors the tax advantages of the partnership such as the pass-through of losses, while at the same time limiting their liability to the original investment The Tax Reform Act of 1986 changed the situation considerably, however IRC Section 465 generally limits a partner s loss to the amount that the partner has at risk and could actually lose from an activity These rules, which apply to individuals and certain closely held corporations, are designed to prevent taxpayers from offsetting trade, business, or professional income with losses from investments in activities that are, for the most part, nanced by nonrecourse loans for which they are not personally liable If it is determined that the loss is deductible under these at-risk rules, the taxpayer is subjected to passive activity loss rules Generally, losses from passive trade or business activities, such as in a partnership where the partner is not active, may not be deducted from other types of income such as wages, interest, or dividends according to IRC Section 469 Some substantial tax bene ts can still be enjoyed by investing in a triple net lease limited partnership These partnerships buy buildings that are used by fast-food, auto parts, and other chains and franchises that do not want mortgage debt on their balance sheet The partnerships collect rent and pass it along to the partners net of three costs insurance, upkeep, and property taxes paid by the tenants (d) IMPORTANCE OF PARTNERSHIP In the United States, the single proprietorship is the most common form of business organization in terms of number of establishments, and the corporate form does by far the greatest volume of business Nevertheless, the partnership form of organization holds an important place in both respects and lls a signi cant need It is widely employed among the smaller business units and in professional elds such as medicine, law, dentistry, and accountancy, activities in which the partners are closely identi ed with the operation of the business or profession Partnerships are also found in nancial lines, such as investment banks Occasionally a substantial trading or other business is conducted as a partnership (e) FORMATION OF PARTNERSHIP The agreement among the copartners that brings the partnership into existence may be oral or written The latter is much to be preferred Note the following from Bedford, Perry, and Wyatt:.

International index of erectile function (IIEF) [48]

Since a partnership is based on a contract between two or more persons, it is important, although not necessarily a legal requirement, that special attention be given to the drawing up of the partnership agreement This agreement is generally referred to as the Articles of Copartnership In order to avoid unnecessary and perhaps costly litigation at some later date, the Articles should contain all of the terms of the agreement relating to the formation, operation, and dissolution of the partnership2

Each partner should sign the articles and retain a copy of the agreement It is desirable that a copy of the agreement be led with the recorder, clerk, or other of cial designated to receive such documents in the county in which the partnership has its principal place of business In the

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The IIEF was originally developed to evaluate the clinical ef cacy of sildena l (Viagra ) and became the most accepted and used ef cacy tool for drugs assigned to treat ED world wide It comprises 15 questions in ve domains, addressing erectile and orgasmic function, sexual desire, sexual satisfaction and overall satisfaction Each question has six response options scoring between zero (worst) and ve (best result) For evaluation of the erectile ef cacy of a drug the IIEF erectile function (EF) domain, comprising questions 1 5 and 15, represents the strongest ef cacy tool, with a score >25 indicating a normal erectile function

Choose Insert Convert to Symbol and make it a movie clip named myPic (or myPicwText) Position the filmstrip so that the leftmost image is centered horizontally on the Stage In the Property inspector, type myPic in the Instance Name text box

Norton M Beford, Kenneth W Perry, and Arthur H Wyatt, Advanced Accounting An Organization Approach (John Wiley & Sons, New York, 1979)

33 39

Sexual encounter pro le (SEP)

Utility plant in service Accumulated depreciation Construction work-in-progress Plant capacity Mw Company s share In-service date $XXX,XXX $XXX,XXX $ XX,XXX XXX XX% 1974

$XX,XXX $XX,XXX $ XX XXX XX% 1981

The sexual encounter pro le relies on the recordings of the patients in the patient diaries distributed to the patients with the study medication and collected at each study visit The SEP comprises the following ve questions: 1 Were you able to achieve at least some erection (some enlargement of the penis ) 2 Were you able to insert your penis into your partner s vagina 3 Did your erection last long enough for you to have successful intercourse 4 Were you satis ed with the hardness of your erection 5 Were you satis ed overall with this sexual experience

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