Major J., after noting that both parties to the appeal accepted that the taxpayer's interest in a piece of undeveloped land was held in connection with an adventure or concern in the nature of trade ("a legitimate "scheme for profit-making',") indicated his agreement with this characterization, finding (at para. 18) that the critieria in IT-218R as to what is a real estate adventure in the nature of trade were satisfied:
The apellant and his associates purchased the Styles Proprty with the intention of reselling it at a profit. ... The persons involved in this venture were experienced business people who treated the transaction as a business venture. The land involved was undeveloped real estate which was suitable for resale but unsuitable as an income producing investment or for the personal enjoyment of the appellant or his associates.