Marine Petroleum Trust (the Trust) is a royalty trust. The Trust and its subsidiary cannot engage in a trade or business. The Trust's wholly owned subsidiary, Marine Petroleum Corporation (MPC), holds title to interests in properties that are situated offshore of Louisiana. Ninety-eight percent of all oil, natural gas, and other mineral royalties collected by MPC, less the receiving and collection costs, are retained by and delivered to the Trust. MPC retains the remaining two percent of the overriding royalties along with other items of income and expense until the board of directors declares a dividend out of the corpus. MPC, like the Trust, is prohibited from engaging in a trade or business and only takes those actions that are necessary for the administration and liquidation of its properties. MPC and the Trust are focused on the purpose of administration and collection of royalties.