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. … In sum, I am of the view that the debt claim bequeathed to the Taxpayer was transferred to her on November, 12, 2008, being the date of death of Mr. ...

. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...

He stated (at para. 64, TaxInterpretations translation): [T]he simple fact of wishing to obtain a better price on the sale of the immovable is insufficient for concluding that a taxpayer was engaged in an adventure or concern in the nature of trade; a taxpayer engaging in a project carrying risk or having a commercial character is not necessarily carrying on a business …. ...

Whether the property was a “former business property” turned on whether (under the definition thereof) it qualified as a “property … leased by the taxpayer to a person related to the taxpayer and used by that related person principally for any other purpose.” ...

The appeal judge did not … fail to consider any relevant factor. ...

. … [It] simply could not take advantage of the proceeds of the illegally obtained warrants. ...

. … The Agricultural Activities are not carried on independently of the Manufacturing and Processing Activities given Lunick Farm's strategy of vertical integration. ...

In dismissing their appeal, Bouchard JCA indicated that the fact that this was an isolated transaction and that they were not “flippers” was not decisive, the judge had not erred in noting the complete absence of any business plan or other documentary proof of their lack of motivating intention to sell (although, he noted, at para. 34, TaxInterpretations translation, and before referring to Hickman Motors in this regard) that “it is true that there are exceptional situations where the taxpayer manages to demolish the ARQ's assumptions of fact despite the taxpayer’s evidence being limited to the taxpayer’s testimony”) and (at para. 44) that “the judge did not commit a reviewable error … by holding that the appellants had a secondary intention to divest themselves of their project in the event of an interesting offer being made to them.” ...

. … While section 54 ensures that stock option benefits are subject to sections 49 et seq. of the T.A. and excludes them from the scope of sections 36 and 37 [equivalent to ITA ss. 5, 6], it is not, in the absence of clear legislative indications to that effect, a code so complete and airtight that the application of section 422 is excluded. ...

Before confirming the ARQ view (and reversing the decision below), the Court noted that the daughter was not subject to Quebec income tax, referred to the Oceanspan decision as being “particularly illuminating” (para. 44, TaxInterpretations translation), and further stated (at para. 45): The Oceanspan decision was recently cited … in the Marino decision. ...