The Queen v. Irving Garber Sales Canada Ltd., 92 DTC 6498, [1992] 2 CTC 261 (FCTD) -- summary under Subsection 129(4.1)

The taxpayer, which was engaged in the sale of raw fur skins and of manufactured fur coats, had its holdings of certificates of deposit grow from $285,000 to $623,000 from 1978 to 1982. Although the taxpayer's other assets (mainly accounts receivable of up to $16,000) were relatively minimal, Joyal J. found that $200,000 of the certificates of deposits constituted a reasonable reserves for the exigencies of the taxpayer's business (so that the income thereon was active business income) in light inter alia of the need to demonstrate financial stability in order to participate in fur auctions and the fact that it was at risk for the full amount of each individual purchase of furs which, in some cases, were substantial.