Two individuals own land and lease the land to a tenant. The tenant pays all taxes, utility

bills, and other assessments relating to the land. The only activities of the individual who

own the land are collecting the rent from the tenant. Based on these facts, which of the

following is the best analysis?

The individuals are merely co$-$owners because they have not filed a partnership tax return so it is

clear that they did not intend to be partners.

The individuals are partners because they are leasing property.

The individuals are merely co$-$owners because they are not carrying on a business activity and they

are not sharing profits.

The individuals are partners because without a partnership, it will be very difficult to properly reflect

income from the leasing activity.