The taxpayer was a professional engineer working as a project manager through corporations controlled by him and employing him. Over the course of six years, he made four loans. In finding that the taxpayer was in the business of lending money, so that bad debt losses could be deducted under the pre-1994 version of s. 20(1)(p)(ii), Bonner J stated (at para. 12):
He evaluated the lending opportunities and considered both the potential gain for himself and the ability of the borrowers to repay. He obtained security when possible. The loans appear to have been made at ordinary commercial rates of interest. The loans though few in number, were not remarkable for any feature which distinguished them from the operations of an ordinary commercial money-lender. …[T]he appellant expected to earn money on the spread between the two rates and thus to mimic the operations of other commercial lenders.