The
Assistant
Chairman:—The
appellant
has
appealed
to
this
Board
from
an
assessment
for
income
tax
for
the
1974
taxation
year.
The
appellant
admits
that
he
had
a
taxable
capital
gain
with
respect
to
the
sale
of
certain
shares
in
1974,
but
disputes
the
quantum
of
such
gain
as
computed
by
the
Minister.
In
March
of
1970
a
corporation
was
incorporated,
pursuant
to
the
laws
of
the
Province
of
Alberta,
called
Town
and
Country
Mobile
Home
Sales
Ltd
(hereinafter
called
“Sales”)
for
the
purpose
of
selling
mobile
homes.
Initially,
after
organization,
Sales
had
four
shareholders.
In
the
late
spring
of
1970
that
number
was
increased
to
five
and
it
so
remained
until
about
the
end
of
December
1971,
when
one
shareholder
sold
his
shares
to
the
remaining
shareholders.
In
March
of
1974
three
of
the
four
shareholders
sold
all
their
shares
to
the
fourth
shareholder.
It
was
this
transaction
which
gives
rise
to.
the
question
to
be
resolved
in
this
appeal.
In
mid-April
1970
(about
a
month
and
a
half
after
the
incorporation
of
Sales)
the
same
four
original
shareholders
of
Sales
together
with
another
person
(the
one
who
became
a
shareholder
of
Sales
shortly
after
its
incorporation)
caused
another
corporation
to
be
incorporated,
likewise
pursuant
to
the
laws
of
the
Province
of
Alberta.
This
company
was
called
Town
and
Country
Mobile
Home
Sales
(Western)
Ltd
(hereinafter
called
“Western”).
The
purpose
of
its
incorporation
was
also
to
sell
mobile
homes.
The
five
persons
were
shareholders
of
Western
until
the
latter
part
of
December
1971,
when
one
shareholder
—the
one
who
sold
his
shares
in
Sales
in
December
1971—sold
to
the
other
four
shareholders
of
Western
his
shares
of
Western.
From
December
1971
the
shareholders
remained
the
same
until
March
of
1974
when
three
shareholders
in
Western
sold
all
their
shares
to
the
remaining
shareholder
of
Western.
This
transaction
becomes
part
of
the
transaction
giving
rise
to
the
question
referred
to
previously.
The
respondent,
acting
on
the
premise
that
the
appellant
sold
shares
in
each
of
Sales
and
Western,
computed
the
appellant’s
gain
after
valuing
the
shares
of
each
company
on
Valuation
Day.
The
appellant
made
his
computation
on
the
basis
that
there
was
really
only
one
transaction.
The
appellant
was.
one
of
the
three
vendors
of
the
shares
in
March
1974.
The
other
two
were
H
Edward
Mildon
and
Gordon
D
Heron.
All
parties
agreed
that
the
result
of
this
appeal
will
be
applied
to
the
appeals
by
the
other
two
vendors.
As
far
as
the
transaction
was
concerned,
the
appeal
proceeded
as
though
there
was
only
one
transaction
with
one
vendor.
To
identify
the
individuals
involved
and
the
events
which
happened,
it
would
appear
best
to
start
about
the
fall
of
1969.
At
that
time
Barry
Tomalty
(hereinafter
sometimes
called
“Tomalty”)
was
a
shareholder,
director
and
salesman
of
Chateau
Homes
Sales
Ltd
(hereinafter
called
“Chateau”),
a
company
selling
mobile
homes
in
the
Edmonton,
Alberta
area.
Prior
to
being
involved
with
Chateau,
Tomalty
had
been
a
salesman
with
an
organization
referred
to
as
“United”,
which
also
sold
mobile
homes.
While
with
that
firm,
he
worked
with
and
came
to
know
an
individual
known
as
Wynn.
Tomalty
had
been
selling
mobile
homes
since
about
1968
and
for
a
year
or
two
prior
to
that
had
been
working
with
a
financial
institution,
I
believe
Traders
Finance.
At
the
time
of
the
hearing
he
was
33
years
of
age.
He
was
not
happy
in
his
association
with
Chateau
where
he
worked
on
a
straight
salary
and
he
sold
his
share
interest
in
it
in
February
1970
for
a
nominal
amount
(the
same
amount
as
he
had
paid)
and
left
Chateau.
While
with
Chateau,
he
met
S
Reesor
Kaufman
(the
appellant),
H
Edward
Mildon
and
Gordon
D
Heron.
One
of
the
lines
of
mobile
homes
sold
by
Chateau
was
the
Muttart
line
manufactured.
by
Muttart
Industries
Limited.
All
of
Messrs
Kaufman,
Mildon
and
Heron
were
employees
and,
I
believe,
responsible
officers
of
Muttart
Industries
Limited.
As
a
result
of
knowing^these
three
persons,
and
following
discussions,
they
and
Tomalty
caused
Sales
to
be
incorporated.
The
four
were
to
be
its
only
shareholders.
Shortly
thereafter,
as
Tomalty
wanted
Wynn
as
an
employee
(he
needed
help)
and
the
four,
not
wishing
to
give
Wynn
a
share
interest
in
Sales,
caused
Western
to
be
incorporated.
Wynn,
with
the
other
four,
became
a
shareholder
of
Western.
Sales,
apparently
shortly
after
its
incorporation,
opened
its
business
of
selling
mobile
homes
in
Prince
George,
British
Columbia.
The
business
continued
there
until
after
the
sale
of
the
shares
in
question
in
March
1974.
Tomalty
was
to
manage
that
operation.
Following
the
incorporation
of
Western,
it
opened
its
mobile
home
sales
lot
on
the
west
side
of
Edmonton.
While
Wynn
became
the
manager
of
that
business,
at
least
at
that
time,
Tomalty
became
its
general
manager
as
well
as
the
manager
of
Sales.
As
between
himself
and
Wynn,
he
had
the
final
say
in
the
operation
of
both
companies.
It
should
be
noted
that
it
appears
that
the
appellant,
Mildon
and
Heron
did
not
take
an
active
part
in
the
day-to-day
operation
of
the
companies.
As
Kaufman
put
it,
they
did
have
formal
monthly
meetings.
In
the
late
spring
of
1970
Wynn
let
it
be
known
to
the
officers
of
Western
that
he
was
unhappy
in
not
having
a
share
interest
in
Sales.
After
some
time
the
shareholders
of
Sales
agreed
that
Wynn
would
have
a
shareholding
in
Sales
the
same
as
he
had
in
Western.
From
that
time
until
late
December
1971,
each
company
had
the
same
shareholders
and
each
shareholder
had
the
same
number
of
shares
in
each
company.
Notwithstanding
that
Wynn
became
a
shareholder
of
Sales,
friction
arose
between
him
and
Tomalty
late
in
1970,
which
continued
on
until
Wynn
left
both
companies.
Tomalty
spent
considerable
time
in
Prince
George
as
Sales
was
having
problems
and
was
not
doing
as
well
as
expected
or
hoped
for.
It
started
to
make
money
in
1971.
As
mentioned,
Western
had
commenced
its
business
shortly
after
incorporation
by
operating
from
a
lot
on
the
west
side
of
Edmonton.
In
the
spring
of
1971
a
decision
was
made
by
Western
to
open
a
second
mobile
home
sales
lot
on
the
south
side
of
Edmonton.
An
office
was
set
up
there
and,
because
of
his
friction
with
Wynn,
Tomalty
moved
his
office
from
the
west-side
lot
to
the
new
lot
hoping
the
friction
would
lessen.
In
the
spring
of
1971
(effective
April
1)
a
further
decision
was
made.
All
business
from
that
day
forward
was
done
in
the
name
of
Sales
and,
in
so
far
as
the
shareholders
were
concerned,
Western
no
longer
existed
from
a
business
point
of
view.
Tomalty
suggested
there
was
no
reason
for
the
two
companies
carrying
on
business
separately—as
they
had
from
about
April
1970—as
now
(April
1971)
all
shareholders
had
an
equal
interest
in
both
companies.
The
accountant
giving
evidence
suggested
it
could
have
been
for
a
tax
reason—to
get
the
profit
of
Western
into
Sales
which
had
a
loss
carry
forward
from
its
1971
fiscal
year.
While
both
companies
carried
on
business
in
different
places
with
different
employees
for
their
first
fiscal
year,
business
operations
were
carried
on
in
a
similar
fashion
and
the
witnesses
did
not
distinguish
between
the
two
companies
when
referring
to
their
operations.
At
about
the
time
operations
commenced—in
early
1970—a
prominent
firm
appeared
on
the
Canadian
market
as
a
manufacturer
of
mobile
homes,
namely,
Atco
Industries
Ltd
(hereinafter
called
“Atco”).
Sales
and
Western
sold
Muttart
and
other
brands
of
mobile
homes
initially.
Tomalty
thought
the
products
of
Atco
had
great
potential
and,
in
due
course,
he
endeavoured
to
get
an
exclusive
franchise
for
the
Edmonton
area
and
presumably
the
Prince
George
area
as
well
although
the
latter
was
not
referred
to.
By
the
summer
of
1971
the
business
did
have,
according
to
Tomalty,
such
a
franchise
for
the
Edmonton
area
although
the
agreement
as
to
such
was
not
in
writing.
No
mention
was
made
of
a
franchise
being
granted
in
the
Prince
George
area.
Evidence
was
led
to
show
that
Tomalty
endeavoured
to
get
the
Atco
franchise
for
the
Red
Deer
as
well
as
the
Grande
Prairie
area,
both
in
the
Province
of
Alberta.
The
Red
Deer
franchise
was
granted
in
the
fall
of
1971,
effective
with
the
1972
products
which
was
February
1972.
The
Grande
Prairie
franchise
was
obtained
by
the
end
of
December
1972
and
business
opened
in
1973.
In
Tomalty’s
opinion,
realistically
while
things
had
been
tough
and
there
were
problems,
the
future
looked
bright—sales
were
up,
Atco
had
a
fine
product,
business
climate
in
the
area
was
good,
the
mobile
home
industry
was
growing,
the
opening
expenses
were
heavy
but
were
really
non-recurring
expenses,
the
name
of
the
company
was
getting
well
established
(presumably
the
name
Town
and
Country
Mobiles),
and
the
business
had
plenty
of
capital.
Of
their
business,
the
company
sold
about
eight
Atco
homes
for
every
Muttart
home
and,
by
the
end
of
1971,
the
business
was
one
of
the
top
three
in
the
industry,
and
being
the
purchaser
of
about
half
of
the
products
manufactured
by
Atco,
Sales
was
its
largest
retail
outlet.
The
lots
from
which
all
activities
were
carried
on
by
either
of
the
companies—at
least
until
the
end
of
1971—were
not
owned,
but
rather
they
were
the
subject
matter
of
an
oral
lease
for
month
to
month
in
an
arm’s
length
transaction.
The
lot
at
the
west
side
of
Edmonton
was
rented
at
about
$400
a
month.
There
were
four
salesmen
for
Western
in
1970
who
were
paid
on
a
commission
basis
at
the
rate
of
5%
of
the
selling
price
of
a
unit,
which
sale
price
ranged
between
$10,000
and
$12,000
per
unit—a
salesman
sold
around
30
units
a
year
and
would
make
$15,000
to
$18,000
per
year.
Tomalty
and
Wynn
were
only
paid
$800
per
month
with
no
commission.
As
previously
mentioned,
the
relationship
between
Tomalty
and
Wynn
deteriorated
and,
while
Tomalty
moved
to
the
Edmonton
south
location
to
minimize
conflict
between
the
two,
the
relationship
did
not
improve.
It
reached
the
stage
in
the
late
summer
that
they
were
not
talking.
Shortly
thereafter
the
shareholders
(except
Wynn)
decided
that
Wynn
had
to
go.
He
left
the
employ
in
mid-September
1971
with
pay
until
October
15,
1971.
When
Wynn
acquired
his
shares
in
the
summer
of
1970
he
paid
“a
very
low
figure”.
Tomalty
was
“not
exactly
sure”
but
said
10¢
a
share.
It
should
be
noted
that
notes
were
due
to
a
bank
and
to
an
acceptance
corporation
for
substantial
amounts,
all
of
which
were
guaranteed
by
the
shareholders.
In
addition,
in
1971
sales
owned
a
parcel
of
land
in
Prince
George
which
it
used
for
its
operations.
It
was
stated
(not
by
a
valuator)
that
the
parcel
of
land
was
worth
$57,000
on
Valuation
Day
and
that
that
amount
had
been
accepted
by
National
Revenue.
It
would
appear
that
a
quick
summary
of
the
sale
of
the
Wynn
shares
should
be
noted.
Because
of
the
friction
previously
mentioned
between
himself
and
Wynn,
Tomalty
left
the
negotiations
with
Wynn
to
the
other
shareholders.
His
salary
arrangements
have
been
mentioned
but
he
still
owned
shares
in
each
company.
The
appellant
negotiated
with
Wynn
as
to
the
sale
of
his
shares,
which
negotiations
extended
from
September
to
December
1971.
Wynn
initially
wanted
$20,000
but
later
reduced
it
to
$15,000
and,
because
his
shares
were
minority
shares,
the
quantum
of
$12,000
was
finally
agreed
upon.
It
was
brought
out
in
evidence
that
Sales
had
passed
a
resolution
in
March
1971
(at
a
time
when
Wynn
was
still
a
shareholder)
that
if
a
shareholder
were
desirous
of
selling
his
shares,
those
shares
must
be
purchased
by
the
other
shareholders
at
90%
of
the
value
placed
on
the
shares
by
the
company’s
auditors.
The
appellant
advised
that
no
value
was
placed
on
the
Wynn
shares
when
sold,
as
a
settlement
had
been
made
with
him.
The
settlement
was
reflected
in
an
agreement
dated
December
20,
1971,
and
by
it
“In
consideration
of
Wynn
tendering
his
resignation
as
an
employee
of
the
Company
(Sales)
the
Company
(Sales)
shall
pay
to
Wynn
the
sum
of
$12,000
.
.
.”.
There
was
no
reference
in
the
agreement
to
Wynn’s
shares.
This
sum
‘of
$12,000
was
paid
to
Wynn
$6,000
in
1971
and
$6,000
in
1972.
The
payment
was
made
in
this
fashion
as,
from
an
income
tax
point
of
view,
it
was
to
the
company’s
(Sales)
advantage.
Tax
was
deducted
from
each
payment
of
$6,000.
There
were
however
two
documents
specifically
referring
to
shares.
Wynn
signed
two
letters,
both
dated
December
2,
1971,
one
referring
to
200
shares
of
Sales
and
the
other
to
200
shares
of
Western.
He
sold
each
of
those
blocks
of
shares
free
of
all
encumbrances
for
$20
per
block.
After
Wynn
ceased
being
a
shareholder
and
an
employee
of
the
company
(1971),
business
was
still
carried
on
from
the
same
three
locations:
Prince
George,
Edmonton
west,
and
Edmonton
south.
As
previously
mentioned,
in
so
far
as
the
appellant
and
his
fellow
shareholders
were
concerned,
there
was
only
a
business
carried
on
by
one
company:
the
other
company,
Sales,
was
inactive.
The
two
Edmonton
locations
used
by
Sales
in
its
business
were
on
leased
property.
There
was
no
written
lease
and
the
lease
was
only
for
month
to
month.
In
late
1971
or
early
1972
Sales
moved
one
of
its
locations
in
Edmonton
but
it
still
only
had
a
month-to-month
oral
lease.
In
the
fall
of
1973
Tomalty
commenced
to
discuss
with
the
appellant
as
well
as
Mildon
and
Heron,
the
possibility
of
buying
all
their
shares
in
both
Sales
and
Western.
Mildon,
on
behalf
of
the
possible
vendors,
apparently
sent
a
letter
to
Tomalty
suggesting
a
selling
price
of
$204,000.
Tomalty
did
not
accept.
Further
discussions
followed
which
culminated
in
a
letter
from
Tomalty
to
the
other
three
shareholders
dated
March
13,
1974,
offering
to
purchase
all
their
shares
for
$150,000.
That
offer
was
accepted
and
the
agreement
was
reflected
in
two
formal
agreements
both
dated
May
21,
1974.
One
agreement
reflected
the
sale
of
all
shares
in
Western
owned
by
the
shareholders
except
Tomalty
for
the
price
of
$10,
and
the
other
agreement
reflected
the
sale
of
all
the
shares
of
the
same
three
in
Sales
for
$150,000.
The
sale
was
duly
completed.
On
his
income
tax
return
for
the
1973
taxation
year,
the
appellant
showed
the
sale
of
his
shares
in
both
Western
and
Sales
(375
shares
of
each)
for
a
total
consideration
of
$40,909.05,
with
outlays.
or
expenses
of
Sales
of
$133.33,
and
an
adjusted
cost
base
of
$24,648.38,
producing
a
gain
of
$16,127.34.
The
adjusted
cost
base
per
share
would
appear
to
be
$65.73
although
it
was
not
shown
as
such.
He
claimed
a
reserve
of
$7,201.94,
producing
a
net
gain
of
$4,462.70.
The
Minister
was
of
the
opinion
that
the
taxable
capital
gain
was
$18,359,
and
consequently,
increased
the
quantum
to
be
assessed
by
$13,896.30.
The
difference
between
the
appellant
and
the
Minister
was
the
value
of
the
shares
on
Valuation
Day.
The
position
of
the
respondent
was
that
the
Sales
shares
were
worth
$30
per
share
on
that
day,
while
the
Western
shares
were
worth
$10
per
share.
Neither
the
appellant’s
objection
to
the
notice
of
assessment,
nor
his
notice
of
appeal
to
this
Board
specifically
states
what
the
adjusted
cost
base
of
the
shares
sold
was,
either
per
share
or
in
total.
The
appellant’s
valuator,
at
the
hearing,
proceeded
on
the
basis
that
there
was
only
one
company
and
one
business,
and
he
valued
that
business
on
Valuation
Day
at
$155,280,
or
$106,755
for
the
shares
owned
by
the
appellant,
Mildon
and
Heron.
This
works
out
to
a
share
value
of
about
$77.64
for
1,375
shares.
The
Minister’s
share
value
totalled
$40
per
share.
Each
party
produced
an
expert
witness
to
indicate
how
he
arrived
at
the
value
of
the
business
or
shares.
The
respondent
was
of
the
view
that
the
value
on
Valuation
Day
could
not
be
arrived
at
by
using
the
average
maintainable
earnings
of
the
companies,
as
Western
was
only
in
business
until
March
31,
1971,
and
for
that
period
of
operation
it
had
a
profit
of
about
$29,000.
However
Sales,
for
the
period
ending
March
31,
1971,
had
a
loss
of
$9,908
and,
for
the
9-month
period
ending
December
29,
1971,
it
had
a
further
loss
of
$8,595.
He
noted
also
that,
as
he
viewed
the
current
assets
and
current
liabilities
of
Sales,
it
had
a
working
capital
deficit
of
about
$70,000.
It
was
pointed
out
that
an
asset
which
he
excluded
from
this
consideration
(leased
mobile
units)
could
have
been
a
current
asset
and,
if
it
were
so,
that
asset
would
virtually
wipe
out
the
working
capital
deficit.
He
drew
attention
to
the
fact
that
Sales’
long-term
debt
exceeded
its
fixed
assets.
And,
of
course,
at
December
29,
1971,
it
had
a
retained
earnings
deficit
of
$19,358.
As
to
Western,
it
was
noted
it
was
not,
at
December
31,
1971,
carrying
on
business
nor
had
it
since
March
31,
1971.
Its
only
asset
was
its
retained
earnings
of
about
$21,000
which
it
had
loaned
to
Sales.
The
respondent’s
expert
concluded
that
those
were
the
factors
to
consider
when
he
came
to
value
the
shares
and
arrived
at
the
conclusion
previously
mentioned.
The
appellant’s
expert’s
approach
was
on
a
maintainable
earnings
basis.
He
made
numerous
calculations
to
his
recapitalization
of
sales
and
earnings
to
“normalize”
them
and,-
after
arriving
at
what
he
considered
in
his
opinion
to
be
the
weighted
average
normalized
net
income
of
$38,820,
he
capitalized
it
at
25%
and
valued
all
the
shares
of
the
company
at
$155,280
at
December
29,
,1971—or
a
share
value
of
$77.64.
To
reach
his
normalized
earnings
for
the
two
periods,
March
31,
1971
and
December
29,
1971,
the
appellant’s
expert,
for
the
first
period,
treated
the
two
businesses
as
though
there
were
only
one.
Then
for
that
period
concluded
that
both
maintenance
and
advertising
expenses
charged
were
not
normal
and
added
them
($34,200
and
$11,809
respectively)
back
to
the
income
before
taxes.
He
then
substituted
what
he
estimated
would
be
normal
expenses
($17,497
and
$6,005
respectively)
and
subtracted
those
amounts,
together
with
a
provision
for
warranty
service
on
sales
of
$8,340,
and
arrived
at
a
normalized
income
before
taxes
of
$33,777,
or
after
taxes
of
$26,346.
Similar
adjustments
were
made
to
the
figures
for
the
period
ending
December
29,
1971,
with
a
net
adjustment
of
$79,108
changing
the
reported
loss
to
a
normalized
profit
of
$70,513,
or
a
normalized
profit
after
taxes
of
$45,057.
The
major
adjustment
in
this
year
($77,800)
was
to
adjust
the
gross
profit
from
10.8%
to
14%
(it
was
15.3%
and
14.2%
for
each
company
at
March
31,
1971,
or
for
them
combined
at
that
time
of
14.7%).
The
adjustments
which
he
made
to
the
figures
were
to
take
cognizance
of
abnormal
expenses
and
to
forecast
the
future.
The
low
gross
profit
in
the
second
1971
period
could
be
explained
by
Muttart
trailers
and
the
fact
that
Atco
products
were
the
ones
to
be
sold
in
the
future—not
Muttart.
This
was
something
which
a
prospective
purchaser
would
take
into
account.
The
issue
becomes:
is
the
figure
submitted
by
the
appellant
or
the
respondent
the
correct
valuation
of
the
apellant’s
shares
on
Valuation
Day,
or
is
it
some
other
figure?
We
have
a
company
which
has
been
in
business
only
about
20
months.
It
is
a
new
business—not
a
successor
to
another
business.
It
was
being
established
by
a
young
man
who
had
been
a
salesman
for
another
company
in
a
similar
venture—when
he
got
out
of
that
company
he
sold
his
interest
for
a
nominal
amount.
One
could
conclude
his
activities
were
not
a
startling
success.
We
have
the
company
operating
from
rented
premises
on
an
oral
monthly
lease.
It
would
appear
to
be
anything
but
a
stable,
well-
established,
permanently
located
business.
It
is
to
be
noted
that
the
general
manager
of
the
company
needed
an
assistant,
or
at
least
help,
but
in
a
very
short
period
of
time,
ill
will
arose
between
the
two
and
steps
were
taken
to
get
rid
of
the
recently
acquired
assistant.
One
of
the
adjustments
made
was
to
normalize
the
“hook-up”,
and
advertising
costs.
How
could
one
predict
what
the
future
held
if
the
land
from
which
the
appellant
carried
on
business
was
rented
premises
and
then
only
on
a
monthly
lease?
It
could
be
the
costs
in
those
respects
in
the
past
would
be
normal
costs
as,
if
a
move
or
two
were
made,
new
hook-up
costs
and
advertising
would
have
to
be
incurred
to
let
the
clientele
know
where
the
business
was
being
conducted.
The
adjustment
to
gross
profit
from
10%
to
14%
seems
to
be
a
major
adjustment.
It
could
be
that
business
was
not
being
operated
profitably
but
it
would
seem
strange
that
a
purchaser,
who
could
effect
improvements
in
the
business
at
no
cost
to
himself,
would
pay
the
vendor
for
those
improvements.
I
do
believe
the
appellant
has
valued
his
shares
on
a
very
optimistic
basis
and
has
reached
a
value
in
excess
of
their
Valuation
Day
value.
The
valuator
for
the
respondent
has
been
too
conservative
and
pessimistic
and
has
not
looked
at
the
business
as
a
viable
enterprise.
It
would
appear
that
the
valuation
was
made
virtually
on
a
break-up
basis.
Business
had
been
carried
on
for
about
20
months.
The
initial
year
was
successful
although
there
was
a
downward
swing
in
the
second
1971
period.
I
cannot
see
that
this
should
cause
all
gloom
and
pessimism.
All
things
considered,
I
am
of
the
view
that
the
value
of
the
shares
on
Valuation
Day
would
be
more
reasonably
stated
to
be
$55
per
share
considering
all
the
factors
which
both
experts
put
forth.
The
result
is
the
appeal
is
allowed
and
the
assessment
remitted
to
the
respondent.
for
variation
so
that
the
taxable
capital
gain
of
the
appellant
is
to
be
determined
on
the
basis
that
the
shares
the
appellant
had
in
Sales
and
Western
are
to
have
an
adjusted
cost
base
of
$20,625,
and
not
$24,648.38
as
claimed
by
the
appellant.
Appeal
allowed
in
part.
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