Gunn v. Canada, 2006 DTC 6544, 2006 FCA 281 -- summary under Subsection 31(1)

The trial judge had erred in rejecting a submission that the taxpayer's cattle farm in "combination" with his law practice was his chief source of income, on the ground that it was necessary, in order to find a "combination" that the farming and other operations were integrally connected in that his farm was a major contributor to the success of his law practice, and his law practice owed its existence or its success to the farm. There was evidence that the taxpayer's farming operations resulted in connections that enhanced the profitability of his law practice and that "his day to day life involved both, and the contacts he made in farming became valuable to his law practice". This represented a "combination" in the most ordinary meaning of that word. Furthermore, his farm and his law practice together comprised virtually all his income and represented most, if not all, of his investment of capital. Accordingly, s. 31 did not apply to his farm losses.