Lamarre Proulx, TCJ. accepted the taxpayer's evidence that he and other investors, who had capitalized a numbered company in order to indirectly purchase a ceramic tile manufacturing plant that had just declared bankruptcy, had no intention to become tile manufacturers and had no knowledge of ceramic tile production but, rather, intended to resell their shares in relatively short order once the plant was in full operation. Accordingly, a loss on income account was realized when their investment became worthless.
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