The taxpayer was an individual resident in Quebec who took the position that her share of income earned by a New Jersey partnership engaged in bottling soft drinks was income from property, so that she was not subject to tax pursuant to Reg. 2601(2). In rejecting this position, Noël, ACJ stated (at p. 5008):
The source here is clearly, a business source. If income from property has any meaning at all, it can only mean the production of revenue from the use of such property which produces income without the active and extensive, business-like intervention of its owner or someone on his behalf. I have in mind, for instance, property such as bonds or debentures or shares or real property which do not require the exertion of much activity or energy in order to produce the revenue. There is no question that the appellant has entered into a partnership here with her mother and sister and this partnership is clearly operating a business from which she receives her share of the profits. …