In finding that the forgiveness of debt used to finance land inventory of a predecessor of the taxpayer occurred on capital account, so that s. 80 rather than s. 9 applied to the forgiven amount, Noel J.A. indicated that, based on the jurisprudence:
"Where a forgiveness occurs with respect to a debt incurred in a borrower-lender relationship entered into to finance the operations of the business, it will usually be treated as an abatement of a capital liability since the forgiveness falls outside the 'normal trading operations of the business'."