Which of the following arrangements would most likely be treated as creating an

"entity" for U.S. tax purposes?

a) Property Gas and Lighting Corp. owns a power station, which it leases to AlwaysReliable Utilities Inc. for 15 years. AlwaysReliable operates all aspects of the facility and pays annual rent of $1,000,000 plus 1% of the utility revenue to Property Gas and Lighting Corp.

b) Marcia gives$2,000,000 to Tommy to purchase and renovate buildings in Queens. Tommy manages all aspects of the project, including renovation and eventual sale of the real estate. Marcia is entitled to 60% of the profits from the sale of each building, and Tommy is entitled to 40% of the profits. Marcia expects to also receive back a proportionate amount of her principal invested after each sale, unless the building is sold at a loss, in which case Marcia expects to lose the investment.

c) Leslie hires Vincent to work as a manager in Leslie's very successful Midtown coffee shop. Vincent's annual salary is $110,000 plus a bonus of 2% of the shop's business profits.

d) Tricia lends to Jodi $100,000 as start-up money for Jodi's designer accessories business. The loan is for a 10-year term and entitles Tricia to 4% interest plus 1% of the designer accessories business revenue.