A deceased person held an interest in a family farm partnership. In the course of finding that the executor could not elect to have s. 70(6) apply to only a portion of the partnership interest, CRA noted that “a partnership interest, even if it is represented by the holding of units with or without identical rights, constitutes a single property of the partner,” and a s. 70(6.2) election could not be made respecting only a portion of a property.
This contrasted with qualified small business corporation shares, for which the election could and was required to be made in respect of a particular number of shares: “each share represents a property in itself.”