References in periodicals archive ?
The Tax Court concluded that no valid partnership was formed by the subsidiaries of Allied and ABN, because to form a valid partnership, the parties must intend to join together to conduct an enterprise.
The court further held that the partner's allocation of profits and losses was improper; the conduct of Allied and ABN demonstrated that the Bermuda agreement, which provided for a guaranteed return on investment for ABN, was the substance behind the formula provided by the partnership agreement.
Combining Minnesota Life's financial strength with Allied Solutions' strengths as an entrepreneurial distributor with a large product array enhances our overall ability to provide clients with best-of-class products and services," said Robert L.