Continental Bank Leasing Corp. v. Canada, 98 DTC 6505, [1998] 2 SCR 298, [1998] 4 CTC 119 -- summary under Purpose/Intention

Before finding the existence of a partnership, the Court stated (at para. 43):

Simply because the parties had the overriding intention of creating a partnership for one purpose does not, however, negate the fact that profit-making and profit-sharing was an ancillary purpose.