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of <h1>Voluntary Group Income Generation Requires Mutual Consent, Collective Intent, and Active Profit-Seeking Collaboration</h1> An association of persons (AOP) under income tax law requires two or more persons voluntarily joining together with a common purpose of producing income. Essential elements include mutual consent, collective intent, and active engagement in income-generating activities. Mere joint ownership or inheritance does not automatically constitute an AOP. The association must demonstrate a deliberate, consensual combination aimed at generating profits or gains.
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