Minister of National Revenue v. Curlett, 67 DTC 5058, [1967] CTC 62, [1967] SCR 280 -- summary under Debt/ receivables

The taxpayer, who made a practice of personally advancing money, at a substantial discount, on second mortgage loans to customers of a corporation owned by him, realized a taxable gain when he disposed of all those second mortgage loans to the corporation. It was not appropriate for the trial judge to characterize the transaction as the sael at a gain of a money-lending business as a going concern gvien that the corporate purchaser was essentially wholly-owned by him and already held the first mortgages on the properties in question.