River Hills Ranch Ltd. v. The Queen, 2013 DTC 1200 [at at 1064], 2013 TCC 248 -- summary under Evidence

Payments received by the taxpayers for the termination of their supply contracts (and thus as compensation for the destruction of their related business operations) were capital receipts notwithstanding that the termination contracts labelled the receipts as "payments for feed and herd health expenses." Before so concluding, Hogan J noted (at para. 51) that "evidence pertaining to the parties' understanding as to the intended use of the [payments] is inadmissible," but found that the parol evidence rule did not prevent him from considering the surrounding facts in order to interpret the agreements. He cited (at para. 35) Ventas for the proposition that a commercial contract is to be interpreted, inter alia, "with regard to objective evidence of the factual matrix underlying the negotiation of the contract."