A professional engineer, his partner in his engineering practice and an architect erected an office building in order that the second floor would be used to house their respective professional operations and the balance rented to others. A sale and lease-back of the building 9 months after its completion was prompted by the financial difficulties of the taxpayer (including as a result of a guarantee given on a performance bond). This sale gave rise to a capital gain (contrary to the finding of the Trial Division and the Board).
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