Yes. Your partnership does not generate ordinary income; the partnership generates investment income (capital in nature).
As such, you have a hurdle of meeting the Section 162 trade or business expense; there is no clear cut definition. Always facts and circumstances.
I'm not telling you one way or the other, just providing some guidance for you to make the decision and understand any risk with one position over another.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
