The taxpayer purchased 40 acres of vacant land in 1992 for $110,000, and allegedly incurred interest carrying charges of $179,000 up until its sale in 2006 for $370,000. Lyons J stated (at para. 45):
In Stirling, the Federal Court of Appeal held that interest on money borrowed to acquire property for the purpose of making a capital gain, rather than an income-earning purpose, is precluded, on disposition, from forming part of the cost of the property and cannot be added to the acb.