Words and Phrases - "substantial interest"

The Minister assessed the taxpayer for excess profits tax on the basis that it carried on a business formerly operated by a partnership, and that the individual who held virtually all the shares of the taxpayer ("Zavalkoff") and who along with two other family members, had been an equal partner of the partnership, had a "substantial interest" in both the taxpayer and the partnership.

Before dismissing the appeal of the taxpayer, Fournier, J. quoted with approval of passage from Palser v. Grinling [1948] 1 All ER 1 (HL) at 11, including a statement that "one of the primary meanings of the word ["substantial'] is equivalent to considerable, solid, or big" and then stated (at p. 1084):

"In the present case, wherein three persons (the father and two sons) are the only partners in the partnership, all three having an equal interest and taking an equal part in the operations of the business of the partnership, in my opinion, each partner may be said to have a considerable and solid interest in the business; in other words, a substantial interest though they do not have a majority or controlling interest."