The HUF can be formed with just two members, one of which is a coparcener. In order to be taxed as a HUF, an entity must have at least two coparceners. If the HUF consists only of a husband and wife, there is only one coparcener. As a result, it will not be taxed in the hands of HUFs unless the funds are received on the partition of a larger HUF. In the hands of a sole coparcener, it will be taxed.