Docherty v. Canada, 2005 DTC 5199, 2005 FCA 93 -- summary under Paragraph 96(2.4)(b)

In finding that the taxpayers were limited partners by virtue of s. 96(2.4)(b), the Tax Court judge correctly relied on the existence of benefits including provisions whereby the partners were not obliged to pay the bills of a company controlled by one of the partners (a taxpayer) until the partnership generated revenues, and an obligation on that company to contribute the instalment payments owing by the partners for the balance of the subscription price for the units, in the event that revenues of the partnership were inadequate to cover the partners' obligations.