0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231 -- summary under Specified Investment Business

storage charges were property income, cf. hotel revenue

The taxpayer, which had two employees including its shareholder, carried on a storage unit rental business.

Before referring to the "principal...

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Tax Topics - General Concepts - Onus Minister's pleading of assumptions of law does not relieve taxpayer from entering a case 106