Before going on to find that the taxpayer had realized an ABIL in his 1994 taxation year, as claimed by him, Hamlyn T.C.J. stated (at p. 2530):
"A debt is usually considered to have become a bad debt when the taxpayer has exhausted all legal means of collection. The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent, pragmatic, businessman. However, the Court must be satisfied that the taxpayer acted in a pragmatic, business like manner in making the determination of uncollectibility. (See Berreti v. MNR, 86 DTC 1719 at p. 1723.)"