After finding that rental condominium properties of the taxpayer represented a source of income and that the interest expense on related borrowings was deductible, McLachlin C.J. stated (at p. 6982) that:
"The appellant's hope of realizing an eventual capital gain, and expectation of deducting interest expenses do not detract from the commercial nature of his rental operation or its characterization as a source of income"
and (at p. 6983):
"In our view, the motivation of capital gains accords with the ordinary business person's understanding of 'pursuit of profit', and may be taken into account in determining whether the taxpayer's activity is commercial in nature."