Irwin v. The Queen, 64 DTC 5227, [1964] CTC 362, [1968] S.C.R. 462 -- summary under Subsection 10(1)

Abbott J. indicated, in obiter dicta that he doubted whether the combined effect of s. 14 of the pre-1972 Act and Regulation 1800 made any change to the principle that for income tax purposes gross profit, in the case of a business which consists of acquiring property and reselling it, is the excess of the sale price over costs, subject only to modification by the lower of cost and market rule, and that he was doubtful that such provisions were applicable in the circumstances of a case (such as that a bar) where the actual cost and sale price of each particular piece of property were well-established.