Zen v. The Queen, 85 DTC 5531, [1985] 2 CTC 313 (FCTD) -- summary under Real Estate

The taxpayer, who at all relevant times was associated with his brother in land acquisition, construction and development and sales transactions, bought vacant land from his brother, erected a small shopping centre thereon, and sold it 15 months from the time of its acquisition for what was held to be a taxable gain. Since it would have been apparent to the taxpayer from the outset that operating profits from the property would be minimal, it was inferred that he acquired and developed the property with the intention of selling it as soon as it was occupied by tenants.