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The amounts so financed during the period from August 25, 1964 to December 31, 1965 were: Mining claims $ 5,000.00 Equipment 25,814.69 Freight and express 696.15 Geophysical expenses 1,082.68 Insurance 333.10 Legal and audit 826.96 Office expenses 23.65 Repairs, gas and oil 1,571.77 Camp expenses 5,537.00 Miscellaneous expense 74.60 Groceries for camp 535.28 Travel expenses 3,504.12 $45,000.00 The purpose of all this—according to the testimony of C C Curlett— was initially, at least, to develop and carry on an operation of recovering and removing for sale crude ore with a high copper content. ...

In Staglines Ltd v Foscalo, Mango & Co, [1932] AC 328, Lord Macmillan in speaking of the rules to be followed in interpreting such conventions, stated at 350: It is important to remember that the Act of 1924 was the outcome of an international conference and that the rules in the schedule have an international currency. ...

Ex D13 is an Air Canada air fare receipted ticket for a trip Dryden to Toronto dated April 28, 1971 $ 56.00 Ex D14 is a requisition (undated) for draft, Canadian Imperial Bank of Commerce, to be paid to Gerard Gagnon. ...

In the balance sheet of the financial statements of the appellant for its financial year ending January 31, 1963 which was appended to the appellant’s income tax return for that taxation year, there is included under the heading ‘‘current assets” an item reading as follows: Fire Insurance Claims — furniture and equipment (as per verbal offer by insurers) $20,000.00 The offer by the insurer to pay the full amount of the coverage on the property here in question forthwith constitutes a waiver by the insurer of compliance with the statutory conditions precedent to payment of the loss. ...

Subsection 152(8) is quite clear and precise, “... subject to being varied or vacated on an objection or appeal to this Part...”. ...

We are thus left with the consideration of the remaining part of paragraph 44(2)(c) namely “... or use for other commercial or mercantile purposes”. ...

When his appeals to the Tax Review Board (unreported) and the Federal Court — Trial Division (78 DTC 6099) were dismissed, the taxpayer appealed to the Federal Court of Appeal. ...

I would also note that it is a well-established practice in tax law to look behind the form of an agreement to determine its substance: see Front & Simcoe v. ...

The expense was incurred for the purpose of producing an income-earning facility — the 72-room addition. ...

.: — The Plaintiff herein filed a Statement of Claim in which he appealed Notice of Reassessment No. 1911903, dated July 13, 1989 (the “Second Reassessment”) in respect of his 1981 taxation year. ...