Dubienski,
D.J.T.C.
[Orally]:
—I
think
on
the
basis
of
the
evidence
before
me,
including
all
comments
in
the
statement
of
facts
supplied
by
the
appellant,
that
the
initial
endeavours
with
Mr.
Potter
of
Delta
Information
Services
Inc.
was
for
the
purpose
of
negotiating
a
joint
venture
or
a
corporate
partnership
and
the
appellant
assessed
the
income
out
of
Wyatt
Corp,
and
that
is
satisfac-
tory
for
the
purposes
and
it
refers
throughout
the
patricular
emphasis
upon
the
investigations
or
inquiries
with
the
Canon
TX
50
equipment.
It
appears
incidental
that
there
were
no
other
matters
that
were
looked
into
by
Mr.
Wyatt
on
his
own
behalf
for
covering
his
own
endeavours
and
it
seems
to
me
that
that
is
where
the
problem
has
arisen,
that
the
divisions
were
not
clearly
enunciated
and
not
clearly
put
forward
particularly
with
regard
to
statements,
documentation
and
accounting
given
to
the
Department.
I
find
that
I
can
make
a
differentiation
fairly
quickly.
I
do
so
find
that
insofar
as
those
activities
conducted
by
Wyatt
on
behalf
of
the
development
of
the
relationships
with
Delta
were
not
purely
advisory
and
were
not
purely
investigatory
which
would
bring
it
clearly
within
the
purview
of
the
Squire
case.
With
regard
to
what
other
expenses
were
incurred
for
investigation
of
the
group
homes
and
the
other
investigations
on
behalf
of
Wyatt
themselves,
I
think
they
are
legitimate
expenses
and
should
be
allowed.
However,
it
will
have
to
be
incumbent
upon
Wyatt
to
establish
clearly
what
those
are
and
that
they
are
for
corporate
purposes
and
nothing
for
personal
benefit.
The
attendance
at
the
trade
fairs
I
think
are
legitimate
and
also
I
am
satisfied
with
the
investigation
with
regard
to
the
group
homes
for
young
offenders.
So
I
would
disallow
the
appeal
as
it
refers
to
matters
concerning
the
relationship
between
the
appellant
Wyatt
Group
Inc.
and
the
Delta
people
but
I
would
refer
the
matter
back
to
the
Minister
for
purposes
of
establishing
those
expenses
that
have
to
do
with
other
matters
in
direct
relationship
with
Wyatt
and
the
reassessment
on
that
basis.
Appeal
allowed
in
part.
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