99. Liability of partnership to income tax and corporation tax.

Since a partnership has, in English law, no separate legal identity, but is recognised as nothing more than a useful means by which to refer to all the partners who, from time to time, make up the partnership, there would prima facie appear to be no reason for any special provisions to apply to partnerships in relation to income tax; each partner's liability therefor could simply be treated as part of his own individual taxation liability1. For example, where a trade or profession is carried on by persons in partnership, the partnership is not, unless the contrary intention appears,