Before accepting largely uncorroborated evidence of the taxpayer respecting his reasons for acquiring a property, Owen J stated (at para. 76):
In Hickman Motors Ltd. v. Canada, [1997] 2 S.C.R. 336, Justice L'Heureux-Dubé made the following comments at paragraphs 87 and 88, which were adopted by the Federal Court of Appeal in House v. The Queen, 2011 FCA 234 at paragraph 56:
. . . Furthermore, where the ITA [Income Tax Act] does not require supporting documentation, credible oral evidence from a taxpayer is sufficient notwithstanding the absence of records: . . . .