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SECTION 22

CO-OWNERSHIP
Not subject to tax if the activity of the co-owners are
limited to the preservation of the property and the
collection of income therefrom (effect: co-owner is
taxed individually on his distributive share)
Should co-owners invest the income of the oownership in any income producing properties,

partnership is subject to tax as a corporation (De


Leon v. CIR)
PARTNERSHIPS
Sharing of profits in a common property does not itself
establish a partnership in the absence of a clear intent
to form the same
Character of habituality peculiar to busine

Reviewer: NATIONAL INTERNAL REVENUE CODE by De Leon | Danika S. Santos


(3B)

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