Is a business continuing to carry on in the year after completing the winding down of its activities?

As I wrote in Caballero v. The Queen, 2009 TCC 390, at paragraph 6: It is possible to commence to carry on a business for purposes of the Income Tax Act (the “Act”) before the business is operational. A business can be expected to have different types and different levels of activities throughout its course. What it does during its start-up or winding down phases can be expected to differ significantly from what it does during its operational phase. It may even have periods of relative dormancy when its normal operations are interrupted. In this case, I find we have a business that is continuing to be carried on in the year in question in the course of completing the winding down of the farming activities it had ceased to operate.