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The memorandum contains the following: (1) The third week’s draw in each month in Corbett & Montgomery payable to Paul E. ...

It is impossible to give effect to the appellant's argument in light of the decision of the Federal Court — Trial Division in George A. ...

.: — The appellant, John Hoare, appeals from reassessments by which the Minister of National Revenue added to the appellant's income amounts of $4,296, $4,954 and $10,000 for the taxation years 1979, 1980 and 1981 respectively, on the basis that these amounts were income earned from a business carried on by the appellant. ...

Justice Cattanach was dealing with the taxation years 1977, 1978 and 1979 which followed the point in 1975 and 1976 where the appellant was, to quote His Lordship, “... able to embark upon the pig farming operation he had planned to the extent he had envisioned.” ...

Gibson of the Tax litigation section of the Department of Justice as follows: Bank of Montreal June 26-74 $ 7,150.29 Bank of Montreal June 25-75 4,971.01 Niagara Finance June 28-71 1,092.81 Third mortgage July 20-77 8,400.00 Royal Trust July 26-74 10,089.00 Bank of Montreal June 14-74 9,978.59 $41,681.70 In filing his income tax return for the taxation year 1979 the appellant claimed as a deduction in computing his income an allowable business investment loss in the amount of $21,305.88. ...

In construing a penal section there is the unimpeachable authority of Lord Esher in Tuck & Sons v. ...

Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in this case are subsection 2(1) and paragraphs 3(a), 12(1)(j), 82(1)(a), (b), 122.2(1)(a), (2)(b). ...

Giffen and Craddock from the farm were as follows: 1979 (4 months) $ 3,863 1980 11,295 1981 14,999 1982 14,998 1983 14,999 1984 4,938 Messrs. ...

The said Exhibits read as follows: GORDON WRIGHT SCHEDULE 1 EARNINGS AS A COMMERCIAL FISHERMAN 1976 16,866 1977 16,649 1978 40,058 1979 36,888 1980 7,406 1981 26,824 1982 19,604 1983 15,751 180,046 GORDON WRIGHT SCHEDULE 2 EARNINGS FROM ROE HERRING FISHERY 1976 7,577 1977 6,223 1978 10,406 1979 22,748 1980 strike 1981 did not participate — gambling 1982 4,538 1983 14,202 65,694 It may be seen, with respect to roe herring fishing, there was a strike in 1980, no income in 1981, and a small income in 1982. ...

The evidence showed that the farming business was, for the most part, dependent on the renting out of four saddle horses — usually a seasonal activity, the sale of maple sugar products, the sale of wood in 20 years’ time, the sale of honey, the sale of a small amount of livestock for butchering. ...