Jisoo transferred his two 4 parcels of land to his 2 children to enable them to build their residence. One year after the transfer, the children resold the lots dividing the proceeds among themselves, treating the same as capital gains and paying proper income tax. Later, the BIR required the children to pay partnership income tax, arguing that the children formed an unregistered partnership or joint venture. Is the BIR correct? why or why not?