De Benveniste v. Christensen Family, LP, et al., 682 S.E.2d 529 (Va. Sup. Ct. 2009)

(limited partner, as co-tenant, must share cost of subdivision preparations for partnership asset (350-acre showplace cattle farm) with other limited partners; expenses incurred with intent to maximize sale value of farm by dividing it into a 68-lot subdivision and rule of contribution among co-tenants applies and the securing of preliminary subdivision plan was a permanent improvement; plaintiff did not consistently oppose pursuit of subdivision plan and alleged procedural defects in application for subdivision plan does not provide plaintiff grounds for asserting that other limited partners acted with unclean hands).