The taxpayer, which engaged in research as to techniques for maximizing the yield from pig farming operations and, consequently, derived significant revenues from the sale of pigs, deducted such revenues from its expenses in its financial statements.
The only business of the taxpayer was its research business (so that it did not have another business of a commercial pig farm). Furthermore, even if the proceeds of sale of pigs should be taken into account (rather than their deduction from expenses being accepted), such proceeds of sale would still be derived from the taxpayer's research activities, so that it satisfied the "substantially all of its revenue" test in s. 37(8)(c).