Rev. Rul. 55-606

A so-called partnership consisting of officers of a bank was organized for the sole purpose of accepting and holding legal title to personal property, including stocks, bonds, notes and other securities, as nominee or agent of the bank. Under the terms of the agreement, the partnership has no capital, income, expenses or any beneficial interest in any of the personal property or securities held by it as nominee, nor does the partnership or any member thereof receive any compensation for their services. Held, a so-called partnership formed under such circumstances for the purpose of acting solely in the capacity of a nominee or agent is not required to file a partnership return. However, such nominee or agent is required to file an information return 1954 disclosing the actual owners of the income received from the personal property held by it as nominee or agent, unless the bank in a fiduciary capacity is required to file a fiduciary return. Pending the promulgation of further instructions, Form 1087, Ownership Certificate-Dividends on Stock, will continue to be used to file information returns disclosing the actual owners of income as set forth in section 39.147-8 of Regulations 118, made applicable under the 1954 Code by T.D. 6091, C.B. 1954-2, 47