The taxpayer (Mr. X) accumulated over 35 years a collection of objects from an era out of a passion for objects from that era. Over the years, he exchanged and sold certain objects with the aim of obtaining new items for his collection. He then made a decision to dispose of the items in his collection, and sold the items one by one to different buyers on an auction website.
After indicating that the objects likely were acquired as capital property, CRA stated that “the fact that the objects were offered for sale on an Internet auction site is not, in our view, sufficient in itself to conclude that there was a change of use.”