A partnership in whose farming business the partners are actively involved owns the residence of one of the partners, who does not pay rent, but pays all the annual expenses of the residence. After noting that except for s. 12(1)(y), there is no statutory provision applying to a partner by reason of the partner’s personal use of partnership property, and also indicating that such personal use was relevant to s. 103(1), CRA went on to state:
[T]he partnership would not be permitted to deduct any operating costs or any other costs or portions of costs relating to the partner's personal use of the capital property.