From 1960 to 1997, the classification of unincorporated business associations for the purpose of U.S. federal income tax law was governed by the so-called ""Kintner" regulations," which were named after the prevailing taxpayer in the 1954 legal precedent of that name. As promulgated by the Internal Revenue Service (IRS) in 1960, the "Kintner" regulations set forth a complex six-factor test for determining whether such business associations would be taxed as corporations or partnerships. The Wyoming LLC statute was tailored by the Wyoming Legislature to exploit an important flaw in the "Kintner" regulations—all six factors were supposed to be of "equal significance". This part of the regulations implied that it might be possible to structure an entity with both limited liability and pass-through tax treatment by meticulously balancing the six factors against each other.