Funds that were surplus to the day-to-day requirements of the taxpayer's concrete business were invested by it in interest-bearing term deposits. Sarchuk J. stated:
"I am not satisfied that the evidence adduced establishes a financial relationship of dependence of some substance between the term deposits and the active business carried on by the appellant or that the appellant relied on the term deposits as an integral aspect of its business operations ... There is no cogent evidence as to the amount of cash reserves required on an ongoing basis, e.g., for truck replacement."
Similarly: Transport Lacté Inc. v. MNR, 89 DTC 606 (TCC)