Heald,
J.A.:
—
In
spite
of
the
able
and
extensive
argument
by
counsel
for
the
appellant,
we
are
not
persuaded
that
the
learned
trial
judge
committed
reviewable
error,
either
in
his
appreciation
of
the
factual
situation
in
this
case
or
in
his
application
of
the
relevant
jurisprudence
to
the
facts
as
found
by
him.
Furthermore,
considering
the
finding
made
by
the
learned
trial
judge
that
dentistry
was
the
appellant's
chief
source
of
income
and
that
his
ranch
was
a
sideline
operation,
and
being
of
the
view
that
such
a
finding
was
reasonably
open
to
him
on
this
record,
we
think
it
unnecessary
to
add
the
appellant's
alternative
submission
to
the
effect
that
the
appellant
had
two
sources
of
income
(farming
and
dentistry),
that
neither
source
was
clearly
subordinate
to
the
other,
and,
thus
the
appellant's
chief
source
of
income
was
"a
combination
of
farming
and
some
other
source
of
income”
as
those
words
are
used
in
subsection
31(1)
of
the
Income
Tax
Act.
Accordingly,
and
for
these
reasons,
the
appeals
will
be
dismissed
with
costs.
Appeals
dismissed.
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