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entered into an agreement to operate a cockpit. Rocky promised to contribute for the capital to start the cockpit amounting to Php 400,000.00. Tammy, having

entered into an agreement to operate a cockpit. Rocky promised to contribute for the capital to start the cockpit amounting to Php 400,000.00. Tammy, having no funds, promised that he will be the one to administer, manage, and be responsible for the operation of the cockpit. Is Rocky and Tammy a corporation in the lens of the National Internal Revenue Code?

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