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Pawnee Petroleums Limited, Maraval Resources Limited and Nassau Petroleums Limited v. ... The prime object of the company was: to acquire, explore for and produce petroleum, natural gas and all related substances and minerals. 1965 Debits Debits Credits Balance July 28 Deposit $51,000.00 $51,000.00 July 28 Deposit $11,028.00 July 28 Deposit $ 8,272.00 $70,300.00 July 28 Pawnee Petroleums $50,000.00 $20,300.00 July 29 Alexy Spivack $ 1,000.00 $19,300.00 Aug. 3 Maraval Resources $ 8,272.00 $11,028.00 Aug. 3 Nassau Petroleums $11,028.00 — Mr Hilland, who in 1965 was the president of Nassau, said that company had taken a passive interest or put in another way, “had followed along with whatever Pawnee elected to do in the matter of settlement of the litigation with California Standard”. lt is to be remembered that Nassau acquired its 25% interest in the Renke lease from Pawnee on March 31, 1965, that is something more than one year after the litigation had been commenced and some two or three months before the action went to trial. ... Court costs and disbursements arising out of the aforesaid legal proceedings shall be borne as follows: Pawnee 371/2 % Nassau 25% Donaldson 18 /4% Maraval 18 / If the above correctly sets forth our understanding herein would you please execute and return a copy of this letter thereby concluding our agreement in this matter.” ...

The Taxpayer, CLARENCE DAIGLE & FILS LTÉE, (hereinafter referred to as the “Taxpayer”), is a Company incorporated under the laws of the Province of New Brunswick and at all times material to the appeal carried on business in the Province of New Brunswick. 2. ... In 1975, the appellant company started on an experimental base to till the soil for the Department of National Resources, with an old equipment. 2. ... Also, the appellant company’s main business activity, as mentioned in its 1977 income tax return, was that of excavation and road gravel contractor, and the scarification contract with the Department of National Resources was not in the nature to qualify the equipment as being used primarily for the purpose of farming. ...

Nomad Sand & Gravel LTD v. Minister of National Revenue, [1982] CTC 2035, 82 DTC 1070 The Chairman:—The appeal of Nomad Sand & Gravel Ltd is from assessments with respect to the 1974, 1975, 1976 and 1977 taxation years. ... The appellants, pursuant to Regulation 1201, also sought to deduct / of their profit from the business by claiming that gravel was a mineral resource. ... As I see it, both the Minister and the presiding Member were of the view that gravel was not a mineral resource. ...

Antares Oil & Gas LTD (In Liquidation) v. Minister of National Revenue, [1983] CTC 2157, 83 DTC 139 The Assistant Chairman:—Antares Oil & Gas Ltd (hereinafter referred to as the “appellant” or “Antares”) has appealed to this Board from assessments of income tax for the 1977 and 1978 taxation years. ... The appellant’s contention was that H Bay agreed to buy certain Arctic permits on December 31, 1975 and that, also on that same date at 5:00 pm (after the H Bay deal), Antares agreed to buy all remaining resources. ...

The financial statement filed with the appellant’s tax return showed: JAMES CONJA — DESIGNER STATEMENT OF INCOME FOR THE YEAR ENDED FEBRUARY 28, 1977 FEES $14,935 EXPENSES Advertising and promotion 1,909 Business use of residence 950 Office supplies 667 Travel 615 Bookkeeping 513 Capital cost allowance 368 Trade publications and fees 623 Equipment rental 166 Insurance 154 Interest and bank charges 258 Maintenance 69 6,292 NET INCOME $ 8,643 CAPITAL COST Undepreci Undepreci- Undepreci ated Capital Adjusted ated Capital Cost Undepreci- Capital Cost Cost February ated Capital Cost February 28/76 Additions Cost Cost Allowance 28/77 Office equipment $ 528 $ — $ 528 $106 $ 422 Technical library 1,230 80 1,310 262 1,048 $368 Prepared without audit for income tax purposes. WM EISENBERG & CO Chartered Accountants The respondent relied, inter alia, upon the provisions of paragraphs 18(1)(a) and (h) of the Income Tax Act, SC 1970-71-72, c 63, as amended, and noted as follows in the reply to notice of appeal: — The appellant was self-employed in 1977. — Throughout the whole of his 1977 taxation year, the appellant worked as a designer on contract with Franteck Investments of Canada Ltd, now known as Modern Technical Services Limited: — pursuant to this contract the appellant was assigned to work for the Ontario Ministry of Natural Resources (“Ministry”); — this assignment necessitated that the appellant work only at the premises of the Ministry; — in filing his 1977 income tax return the appellant deducted from income expenses in the amount of $5,333.66 which were not expenses or outlays made or incurred to earn income during that taxation year; if incurred, the said expenses were personal expenses of the appellant. ... In view of the fact that his income all came from one source — Modern — which, in turn, was paid by some form of contract from the Ministry, it is difficult indeed to follow the appellant’s reasoning that some of the expenses were necessary. ...

Alfred David Perry, dept, of Northern Affairs & National Resources, p.o. ...

Development of new reduction furnace — not yet successfully completed. ... Development of improved retort condenser — one new method was devised and adopted. ... Development of filter to eliminate flux — a satisfactory filter to remove flux from metal in sludge. ...

Both witnesses had, by their company, Pearce, Kennedy & Associates Ltd, carried on the business of business valuators and brokers for a period of 14 months. ... In other words, the resource properties of the company were treated as redundant assets. ... Mr Kennedy’s contribution to Exhibit A-9 was the valuation of the company’s resource properties. ...

The parent could not find funds to repay the appellant and it was decided instead to transfer resources. ... The relevant parts of the resolution read: WHEREAS Canadian Hidrogas Resources Ltd has acquired various working interests to mineral rights in a number of producing and non-producing properties; AND WHEREAS Canadian Hidrogas Resources Ltd is in the process of having further appraisal done on such working interests with a view to establishing a more accurate current value of such interests; AND WHEREAS Hidrogas Limited, a wholly owned subsidiary of Canadian Hidrogas Resources Ltd, is desirous of obtaining a portion of such mineral interests from Canadian Hidrogas Resources Ltd to the extent of Two Million ($2,000,000) Dollars. ... The case appears to be somewhat analogous to that considered by Rowlatt, J in H Ford & Co, Ltd v The Commissioners of Inland Revenue (1926), 12 TC 997. ...

Whatever the appellant’s intention may have been when he acquired the wood lots, there is evidence that in 1965 and in later years the appellant decided — for whatever reason — to sell the right to cut timber on his land and thereby became involved in the timber business. ... The auditor felt that the income from the timber berths — which he considered income from a business — amounted to $15,000 in each of the years under review, as indicated in the income tax returns for those years. ... The appellant probably meant to refer to section 1100 of the Regulations when he quoted: For the purposes of this Part and Schedules C and D, each property of a taxpayer that Is (a) a timber limit other than a timber resource property, or (b) a right to cut timber from a limit other than a right that is a timber resource property, is hereby prescribed to be a separate class of property. ...