Debt/ receivables
Richards, "Quick Flips: Capital Gains or Income Treatment?", Canadian Current Tax, April 1991, p. C57. -- attach -- Debt/ receivables
The Queen v. John Woods, 77 DTC 5411, [1977] CTC 597 (FCTD) -- attach -- Debt/ receivables
Minister of National Revenue v. Sissons, 69 DTC 5152, [1969] S.C.R. 507, [1969] CTC 184 -- attach -- Debt/ receivables
Minister of National Revenue v. MacInnes, 63 DTC 1203, [1963] S.C.R. 299 -- attach -- Debt/ receivables
highly speculative business of purchasing mortgages at discount
Minister of National Revenue v. Curlett, 67 DTC 5058, [1967] CTC 62, [1967] SCR 280 -- attach -- Debt/ receivables
sale of mortgage portfolio to own company not characterized as sale of going concern
Steeves v. The Queen, 77 DTC 5230 (FCA) -- attach -- Debt/ receivables
Scott v. Minister of National Revenue, 63 DTC 1121, [1963] S.C.R. 223 -- attach -- Debt/ receivables
in highly speculative business of purchasing mortgages and lease-option agreements at discounts
Lloyd Estate v. MNR, 63 DTC 1349 (Ex Ct), briefly aff'd 65 DTC 5031 (SCC) -- attach -- Debt/ receivables
Wood v. M.N.R., 69 DTC 5073, [1969] S.C.R. 330, [1969] CTC 57 -- attach -- Debt/ receivables
infrequent acquisitions of mortgages at a discount occurred as a sideline personal investing activity