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The check-the-box regulations carried forward the Kintner regulations theme that ordinary trusts were classified and taxed like trusts. These authorities analyze the trust instrument and the specific nature of the trust to determine whether the trustee has the broad power to conduct a business regardless of whether that power is exercised and regardless of the settlor's intent that the trust not be used to carry on a business. Unfortunately, as discussed below, once the business purpose standard is met, the associates standard is also very easy to satisfy....

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