Aldo and Ben each own an undivided one-half interest in a tract of raw land. They construct a driving range on the land, which they lease to Clyde for $3,000 a month, the profit from which Aldo and Ben share equally. Clyde operates the golf range business on the site. What is the tax classification of Aldo and Ben’s relationship?

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Aldo and Ben each own an undivided one-half interest in a tract of raw land. They construct a driving range on the land, which they lease to Clyde for $3,000 a month, the profit from which Aldo and Ben share equally. Clyde operates the golf range business on the site. What is the tax classification of Aldo and Ben’s relationship? Would your answer change if Aldo and Ben later constructed an commercial building on their land, which they then leased to tenants through an agent, who also provided customary services such as security and parking to the tenants? How about if Aldo and Ben then built a swimming pool and “corporate” gym in their building and then charged the tenants an extra fee to use those facilities? What if no extra fee was charged?

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