Furthermore, the judge was clearly in error when he relied on the intention of the taxpayer to get out of the construction business and to redirect its activities to farming operations by 1985, rather than on the actual redirection which was found to have effectively taken place after the taxation years at issue because the taxpayer had agreed to stay on longer than it had planned in order to undertake or fulfil important construction contracts. The fact is, that during the three taxation years, the taxpayer had not yet displaced, to use the words of Dickson J. in Moldowan v. The Queen2, "the centre of [its] work routine".
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