Distinguishing a Partnership From the Co-Ownership of Property

Distinguishing a Partnership From the Co-Ownership of Property

Assume that two individuals, each of whom is engaged in the business of providing whale watching tours, jointly acquire a fishing vessel. Each individual uses the boat in his separate business, and neither accounts to the other for profits earned from his separate use of the boat. Under these facts, will this arrangement be treated as a partnership for tax purposes?

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