A sole proprietorship is a distinct legal entity, separate and distinct from the owner. A general partnership is a voluntary association of two or more persons for carrying on a business as co-owners for profit. Partnerships can be formed without any formalities, and the presence of the required elements of a partnership can be based on the conduct of those in the business. A partner can be held liable to perform on contracts entered into by his partners, but not for the torts of his partners. In a limited partnership, the partners can agree that all partners have limited liability. Limited partners can lose their limited liability protection if they actively participate in management. A corporation is a taxable entity separate and distinct from its owners. The shareholders of a corporation can agree to restrictions on the transfer of their shares. The Sarbanes-Oxley Act of 2002 was passed in reaction to huge losses by shareholders, employees, and creditors that were caused by a number of business and accounting scandals that occurred during the late 1900s and early 2000s. Generally, a corporate director is liable for mistakes in judgment. A limited liability company must file articles of organization with the appropriate state office. In a limited liability company, profits and losses must be shared in the same proportions. For trade secrets to be protected, a business owner is obligated to take all reasonable precautions to prevent discovery of the trade secrets by others. The victim of stolen trade secrets can recover profits made by someone from the stolen trade secret. The surface rights and the subsurface rights for the same parcel of real property can be owned by two different persons. Natural plant life on land is considered real property, whereas cultivated plants are considered personal property. The highest form of land ownership is fee simple absolute.) There is no right of survivorship in a tenancy in common. A parcel of property that is owned as tenants by the entirety can be owned by no more than two owners