Before going on to find that the taxpayer had not made three loans in the ordinary course of a business of lending money, for purposes of s. 20(1)(p)(ii), Bonner TCJ. stated (at p. 2156):
"The borrowing of money with a view to re-lending it at a higher rate of interest is an activity which is distinctly different from the investment of one's savings in mortgage loans. The former activity is strong evidence of the existence of a money lending business. However, I am not convinced that this is what the Appellant did. ... One of the factors which differentiates between loans made as simple investments of capital and loans made in the course of the business of a money lender is continuity."