R. v. Landes, [1988] 1 CTC 124 (Queb. Ct. S.P.) -- summary under Real Estate

The taxpayers through a corporation ("Village International") leased land in the fall of 1966 near the site of Expo 67 and contributed the land to a joint venture whose other parties were to construct 25 temporary chalets on the leased land in order to lodge visitors to Expo 67. The profits realized by the accused on the completion of the venture in 1968 were fully taxable. With respect to a submission that their profit was from the winding-up of an enterprise, and therefore was on capital account, it was held that "the winding-up of the whole operation was clearly foreseen and anticipated, including the disposal and sale of the chalets."