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I can’t say how I arrived at $10,000 — it is just an amount which I considered to be a nominal reasonable value at the time. ...

There was no legal obligation upon Sparkle to make these payments in that they were the obligation of its sole shareholder — Riddell. ...

Total income for the 1980 taxation year $144,011.00 Less: QPP contributions $ 212.00 Unemployment insurance premiums 204.00 RRSP 4,500.00 RHOSP 1,000.00 Financial costs $24,474.00 IAA 27,338.00* Other deductions 51,812.00 51,812.00 57,728.00 Net income 86,283.00 Personal exemptions 3,880.00 Charitable donations 150.00 Interest deduction 1,000.00 Capital loss carried back from 1981 43,511.00 48,541.00 Taxable income $37,742.00 *Point at issue Having regard to the deduction in respect of taxable dividends under s 121 of the Income Tax Act, the appellant stated moreover in the said amended return that he had no tax payable for the 1980 taxation year. ...

Mr Justice Mahoney of the Federal Court — Trial Division held that the defendant was resident in Canada throughout 1972. ...

In deciding this issue the Court considered other cases relied upon by the appellant, including The Queen v Ensite Limited, [1983] CTC 296; 83 DTC 5315; The Queen v Marsh & McLennan Limited, [1983] CTC 231; 83 DTC 5180, as well as the decision of the Federal Court of Appeal in Canadian Marconi Company v The Queen, [1984] CTC 319; 84 DTC 6267. ...

On November 5, 1979, the appellant was employed as president and chief executive officer of Swift Canadian Co Limited (“Swift”) which was a wholly- owned subsidiary of Swift & Company of Chicago (“Swift US”) which, in turn, is owned by Esmark Inc. ...

After purchase the farm operation continued under a 7,- */ crop sharing arrangement with the vendor Mr Clarence Hayes, with Mr Jarvis going out two or three times a year to look at the crop. ...

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being — Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making? ...

According to the figures in Schedules I and II, the appellant’s income and profitability were as follows (all figures have been rounded off to the nearest thousand): Profit from Management Fees, Rentals & Gross Income Leases A Office Profit/Loss from Term Dqxwt from Farming 1987 21,000 30,000 31,000 1988 (95,000) 30,000 82,000 1989 (89,000) 27,000 121,000 1990 (98,000) 40,000 126,000 1991 (44,000) 14,000 103,000 During 1989, 1990 and 1991, the years in appeal, the farming activities of the appellant resulted in the following losses: $89,000, $98,000 and $44,000 respectively. ...

Counsel for the Appellant argued that there are special circumstances in this case, and in the other cases, which warranted the application — acceptance perhaps is a better word, of the due diligence of defence. ...