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Part a: E and F set up a trust to hold money market mutual funds. They appoint G to act as trustee. G has the

Part a: E and F set up a "trust" to hold money market mutual funds. They appoint G to act as trustee. G has the power under the trust agreement to buy and sell different money market funds and other investments. G frequently buys and sell different money market shares where he sees opportunities to make a profit. G receives a fee for his services as the trustee. E and F each own as beneficiaries an undivided one-half interest in the underlying money market mutual fund shares and they each have an equal right to all dividends and gains on the underlying money market mutual funds. (1) Is there is an entity?


 (2) If there is an entity, what is the type of entity for US federal income tax purposes? 


Part b: If your answer to Part a is that the arrangement does form a "business entity" for US tax purposes, who are the "owners" of the entity?

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