Sidney, Steve, and Andrew form a Kentucky limited liability company, PG&S$,$ to operate a retail store selling sporting goods. Sidney and Steve contributed most of the capital to PG&S$,$ and Andrew contributed services and a small amount of capital. PG&S will be operated and managed by Steve. Sidney will be a passive investor, and Andrew will perform services for PG&S$.$ The members agree to share profits and losses equally.

Question $6(18$ points$)$

a$.$ Is PG&S an eligible entity?

b$.$ What type of entity is PG&S if no election is made?

c$.$ Would your answer change if$,$ instead of a Kentucky limited liability company, Sidney, Steve and Andrew form in Ukrainian Aktsionerne Tovaristvo Vidkritogo Tipu to operate their sporting goods business? Assume no election is made.