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Teresa Kus, who filled out the appellant’s medical certificate (see Exhibit A-1), described this condition as follows: | TRANSLATION] Idiopathic ventricular tachycardia indicated by rapid palpitations and dizziness, requiring the implantation of an anti-tachycardia pacemaker, which can be activated only in a hospital emergency room, to interrupt the rapid rate under medical supervision. ...

The Minister made the following assumptions of fact: (b) on or about October 10, 1986, the Appellant and a partner entered into an agreement of purchase and sale for the purchase of a real property located at 41-43 John Street, Port Hope, Ontario (the “Property”) at a purchase price of $139,000.00; (c) on December 9, 1986, Port Hope Investments Corporation (the “Corporation”) was incorporated in the Province of Ontario; (d) on January 22, 1987, title to the Property was registered under the Corporation’s name; (f) on May 27, 1987, the Appellant and his spouse borrowed $125,000.00 from the Canadian Imperial Bank of Commerce by way of a first mortgage secured by their principal residence; (g) on September 17, 1987, the Corporation borrowed $150,000.00 from a company, bearing interest at 14% per annum, by way of a second mortgage secured by the Property; (h) on April 7, 1989, the Appellant and his spouse obtained by way of a second mortgage loan on their principal residence from Canadian Imperial Bank of Commerce the sum of $125,000.00 with interest at the rate of 15.25% per annum; (i) on April 14, 1989, the Appellant and a partner purchased an assignment of the second mortgage on the Property for a consideration of $160,938.49; (j) on April 16, 1991, the Property was sold to Canada Fine Art & Frame for $325,000.00; (m) in the 1992, 1993 and 1994 taxation years, the Appellant claimed carrying charges and interest expenses, in the amounts of $10,711.00, $9,862.73 and $9,803.03,... ...

Proposed operation: Cystoscopy + cystometry. 21 He was then treated with a half-tablet of Ditropan three times a day. 4. ...

There is no evidence before me that any amount of sales would produce a profit. 10 Although there was no business plan as such, the appellant did say in 1987 he thought he would hit Emerald in three or four years. 11 With nine years losses, continuous losses staring me in the face, there is just no way that this enterprise can fit into the criteria to say, or for me to say in my reasons, that this is a business. 12 If the enterprise is not a business, then there is no provision in the Act to deduct any expenses, they become what we call “personal expenses”. 13 The Federal Court of Appeal — the highlight of expense cases was dealt with in the Supreme Court of Canada by Chief Justice Dickson in Moldowan v. ...

In accordance with this provision, Cosmopolitan agrees to execute the promissory note and the subscription form attached to this letter and return the document together with payment of $22,500 to Davis & Company in trust upon acceptance of this letter agreement. ...

He first purchased an apartment property known as Royal Terrace (” Royal”). ...

.: — These appeals were heard on common evidence in Vancouver, British Columbia, under the Informal Procedure, on September 27, 1996. ...

All the documentary evidence — save for the letters to Revenue Canada by Scalia and Van Der Marel — appears to corroborate the essence of the appellants’ testimony and their version of events. ...

Levert); — portrait of Dr. Adrien Sarens, pastel, 25 inches by 19 inches, sold for $400 at the Hôtel des Encans de Montréal on April 7, 1992; and — portrait of a man, 14 inches by 10 inches, pencil crayon, sold for $175 at Fraser-Pinney’s on November 24, 1993. ... He also admitted that the subject of the painting in question was a pastoral scene and that oil paintings of pastoral scenes had sold at Fraser Bros. auctions in Quebec at the following prices: • in December 1979, “Cattle in a Field”, 11 inches by 9 inches, $375; [5] and • on March 12, 1987, “Pastoral Scene”, 18 inches by 24 inches, $650. [6] Mr. ... Tremblay to provide him with receipts for the 1988, 1989 and 1990 taxation years for the same amounts — $11,000 for himself and $2,750 for his wife each year — in exchange for payments corresponding, minus the tax on the paintings, to 25 percent of the receipts that were made in two instalments: the first on March 1 and the second on June I of the following year. ...

The issue before me is not whether the appellant’s chief source of income during the years 1981 to 1986 was farming — counsel concedes it was not — but whether its chief source of income during this period was a combination of farming and selling groceries. ...