In finding that the taxpayer and other investors who made an investment in a building were a syndicate for purposes of s. 20(1)(e), Rothstein J.A. referred, with approval to the following definition appearing in Romano v. MNR, 66 DTC 490, and 500 (T.R.B.):
"Any group of persons who have agreed to pool their resources of money or of specific assets for some common purpose."
He went on to find that various expenses including a commission, mortgage fees and a prospectus preparation fee qualified as expenses of the syndicate rather than the promoter because they became payable only if the closing occurred, i.e., if the syndicate was formed.