Before going on to find that the taxpayer had provided evidence that amounted to a prima facie case that a loss realized by it on a debt owing to it by a corporation was a business investment loss, Bowman C.J. noted (at p. 1072):
"There is authority to support the view that merely because a company is in a period of inactivity it may still be carrying on a business .... it seems, at first blush, unreasonable to assume that for a taxpayer to be allowed an ABIL the debtor company must have to be carrying on an active business when the debt went bad."