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It concluded that due to the owners' relationship as tenants in common, fractional property interests should not be considered partnerships, as long as they meet certain conditions.
In Letter Ruling 200625009, a company and a co-owner had acquired a property and operated it as tenants in common. The co-owner's affiliate was a tenant of the property.
A spouse's death affects the surviving spouse's basis in the principal residence, depending on whether the couple owned the home as community property, joint tenants (tenants by the entirety) or tenants in common. Joint tenancy (and tenancy by the entirety) typically involves rights of survivorship, while tenancy in common does not.
Remember, entities that become tenants in common will often have been in existence long before SPE requirements came into being.
In this case, the partnership opts to become tenants in common, rather than a partnership solely for the purpose of the property sale/exchange.