Gains from the sale of parcels of farm land were held to be fully taxable, notwithstanding that the parcels had been purchased by the taxpayer with the intention that various relatives would farm the properties and thereby benefit from his assistance, in light of: (1) the quick resale of the properties (within one or two years of their purchase) when the relatives proved unsuccessful at, or unable to, farm them; (2) the absence of any option to the relatives to purchase the properties, and the absence of any financial means on their part to purchase the properties; (3) the expertise of the taxpayer respecting the buying and selling of farm land; and (4) the financing of the land purchases through short-term loans. Dubé, J stated (at p. 5265):
[H]owever generous the primary intention be [of assisting the relatives], was there not another major motivating factor behind the acquisition of the properties, namely the possibility of reselling them at a profit? There were four quick transactions, all clothed with the same characteristics: the overt intent to assist a relative, the absence of any written document or any oral promise binding the relative, the short-term financing by the taxpayer, the lack of any apparent financial means on the part of the eventual purchaser, the preparatory cleanup and sowing of the land, the quick resell, the profit. Each one of these elements considered separately may not be determinant, but the repeated combination of the same factors in four successive transactions cannot but establish a clear secondary intention to resell at a profit.