In not less than three pages (double spaced), discuss the factors considered in determining whether an arrangement is a "partnership" for federal income tax purposes. Your discussion should include a comprehensive analysis of the authority (court decisions, Internal Revenue Code, Treasury Regulations, and IRS pronouncements, i.e., Revenue Rulings) that pertain to this issue. The discussion should not focus on the characteristics of an "association" taxable as a corporation, and the resulting classification of the entity as a partnership or a corporation under the Kinter Regulations as those Regulations have been replaced by the new "check the box regulations" under Treasury Regulation 301.7701. The discussion should focus on whether an arrangement between persons creates the existence of a partnership for federal income tax purposes.