Foley v. The Queen, 2003 DTC 1320, 2003 TCC 680 -- summary under Paragraph 96(2.4)(a)

By services, 28 November, 2015

Although the taxpayers were designated as the limited partners of a partnership, each of them was in control of a part of the partnership's business and the two of them together with their father shared control of the whole business of the partnership. Consequently, they were not limited partners, and the at-risk rules did not apply to limit their share of losses of the partnership.

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