In one case, the court found a common tie among members of an association
based on their common ethnic background. It also found that members had a
common goal to improve their social, moral, and intellectual welfare. See
Hip Sing Ass’n, Inc. v. Comm’r, T.C. Memo. 1982-203. Likewise, persons
who join together to promote a common interest, such as a particular method
of fortune telling, can be said to have a common tie. See Rev. Rul. 77-258,
1977-2 C.B. 195. However, mere recitation of common ties in the governing
instrument is not enough; there must be a common tie in fact among the
members