A partnership that was owned by the taxpayer and trusts for his children owned (through a second partnership that was owned by the first partnership and the taxpayer's wife) a triplex, one unit of which was rented (by the second partnership) to her. Archambault T.C.J. found that the expenses of that partnership incurred in connection with the unit rented to the taxpayer's wife (and a pro rata portion of interest on money borrowed to fund his partnership interest) were not incurred for an income-producing purpose.
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