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In the seven years that have passed since the states began to
authorize doctors, lawyers, and other professional practitioners to
organize "professional corporations" and "professional associations,"
the status of these new-style groups under the Internal
Revenue Code has been the subject of a vast polemical literature. With few exceptions, the commentators have been sympathetic to
the view that professional service organizations are "corporations"
as that term is defined by section 7701 (a)(3) of the Code;
but the reasons offered by those who espouse this view are diverse
and contradictory.

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