E.R. Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD) -- summary under Income-Producing Purpose

In 1952, the taxpayer purchased 52 acres of land outside Montreal in order to construct its own facilities for use in research, manufacturing and marketing. The Minister disallowed the deduction of 84% of the municipal taxes on the ground that they related to unoccupied land. Since the vacant land was retained in the reasonable expectation of future expansion for which the land would be utilized, the municipal tax expenditures were deductible.