Ouellet c. La Reine, 2004 DTC 2706, 2004 TCC 308 (Informal Procedure) -- summary under Paragraph 96(2.4)(b)

After finding that an alleged partnership between the taxpayers and others did not exist, Lamarre Proulx J. went on to find that had the partnership existed, the taxpayers would have been limited partners on the basis of the 50% funding of their investment in the partnership by a term loan provided by a person not dealing at arm's length with the partnership and by virtue of options to purchase their partnership interests.