Cesar, Virgilio and Jos are brothers. They borrowed Php 10M from their father David. They used the borrowed money to buy parcels of land. On February 2, 1943, they bought a lot with an area of 3,500 sqm. On April 3, 1944, they purchased 21 parcels of land with an aggregate area of 3,000 sqm. On April 28, 1944, they bought another parcel of land containing 4,000 sqm. In a document dated August 16, 1947, they appointed Virgilio to manage their properties with full power to lease and collect rents thereon. Sometime later, they received an assessment notice from the BIR demanding that they pay Partnership Income Tax alleging that they have formed an unregistered partnership. The brothers denied their allegation stating that there is no such partnership. Is the contention of the BIR correct? Explain