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Farm Operation Employment Expenses Pasturing Fees Income (exclude CCA) Sales Sales and awards 1984 $28,410 $5,097 $ Nil $1,761 1985 28,141 5,014 Nil 1,725 1986 30,483 5,318 1,593 3,075 1987 32,138 5,869 3,114 3,248 1988 31,175 5,605 4,062 1,200 For the years under appeal, the appellant's farming operation produced cash losses of $3,336 in 1984 and $3,289 in 1985. ...

On this date the source disappeared and in view of the interpretation of paragraph 20(1)(c) as set out above the most the appellant can claim is a deductible interest expense for eight days in 1985, which would produce an amount of 8/365 X $5,038 = $110.42. ...

The 1983 statement on the liability page under current liabilities showed bonuses payable 1983 — $60,000 and for 1982, the sum of $90,000 notwithstanding that the interim financial statement for April 30, 1984 had no mention of the bonuses. ...

Following this and examining the substance of the transaction involved it is noted that in one of the exhibits filed with the Court the corporation's accountants, Deloitte Haskins & Sells said, speaking of the directors who authorized the allotment,... they realized that they personally would have to hold a significantly larger number of shares than was currently the case in order to maintain their level of ownership and participation in the company. ...

The details of the Respondent's computation are as follows: Original Cost $198,175.00 Less: writedown for inventory having a market value less than original cost (i.e. obsolescence) 7,000.00 Revised inventory 191,175.00 Less: inventory as reported by Appellant 118,457.00 Understatement of inventory and understatement of income $ 72,718.00 (f) [4] the market value of the obsolete items described in the Appellant's inventory as at December 31, 1983, was an amount of not more than $7,000.00. ...

The Minister disallowed the deductions and the taxpayers appealed to the Federal Court — Trial Division. ...

The relevant amounts were: 1981 1982 1963 Disallowed Supervision Expense $25,599 $21,330 $20,272 Disallowed Wages $ 9,520 $11,360 $10,662 He explained his action in respect of the bookkeeper’s wages on the form T7W-C accompanying the notices of assessment as follows: John McDermott's wages have been allocated between Poole's Fish Market and Riverside Fisheries Limited based on revenues. ...

The deductions claimed by the appellant as employment expenses in 1984 were: Travel (42 trips at 300 km 12,600 km x $0.28) $3,528.00 Living Expenses (21 weeks x 5 days 105 days at $22.00) $2,310.00 Rent $1,725.00 Utilities $ 53.73 The respondent's position, both in his reply to notice of appeal and in his submissions, was that: (1) It was not a term of the appellant's contract with his employer that he pay for the expenses he sought to deduct. (2) The expenses were not incurred while travelling in the course of his employment because: (a) They were incurred while working at his employer's place of business in Medicine Hat, and; (b) He was not travelling because he settled in Medicine Hat for approximately five months, and; (c) The expenses in question were personal and living expenses. ...

.: — The present appeals, heard at Regina on September 28, 1987 are from reassessments for the appellant's 1977, 1978 and 1979 taxation years by appeal 83-781, and for the appellant's 1980, 1981 and 1982 taxation years by appeal 85-1351. ...

A “business”, for purposes of the Act, "includes a... trade... or undertaking of any kind whatever and... an adventure or concern in the nature of trade... ” (subsection 248(1)). ...