Clevite Development Ltd. v. MNR, 61 DTC 1093, [1961] CTC 147 (Ex. Ct.) -- summary under Start-Up and Liquidation Costs

Royalty income of the taxpayer from foreign patents was found to be income from a business as opposed to a mere property holding notwithstanding that it had no business operations to speak of, because previously the patents had been held in connection with a manufacturing operation that the taxpayer had disposed of and because the licences required the taxpayer to assist the licensees (although, in fact, such support was provided by a foreign parent of the taxpayer).