The taxpayer acquired farmland and rented 50% of it to an unrelated farm producer and 50% to a corporation that operated a nursery there and whose shareholders were him, his children and some of his brothers. During that time, the income from the nursery was his principal source of income. Did the farmland qualify as qualified farm property? CRA responded:
Generally, we are of the view that the activities of a nursery can constitute farming if, in fact, it can be shown that those activities involve the cultivation and growth of plants, shrubs or trees and not just buying and selling those products.