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During these vears his agent in Chicago had been Weinberg Bros & Company (hereinafter referred to as "Weinberg”), and he had been active on the telephone each day from the time the market opened at 9 am until he had completed his trading for that day. ...

Mr Neilson went to the head office of Swift & Co in Chicago to make an offer on this piece of property in Calgary, and as a result of this meeting, succeeded in purchasing the property, by Memorandum of Agreement dated March 28, 1969 for an amount of $100,000 payable on the following terms: a $5,000 deposit on signing; $30,000 in approximately one month; $32,500 within 2 Z? ...

On the second page of Mr Kelly’s appraisal (Exhibit A-4), the following is found: DEFINITION OF THE APPRAISAL PROBLEM The property described as Lots 1, 2, 3 and 4 Loretta Avenue east, Lots 1, 2 and 3 Champagne Avenue west and part of Block C Plan 73 containing a land area of approximately 62601 square feet was sold on December 31 st, 1969, for the sum of $395,000 and the vendor and purchaser agreed on the purchase price being allocated on the following basis: Land $35,000 — Improvements $360,000. ...

That until the said promissory note is paid in full, the said shares are to be held on trust by Messrs Ballem, McDill & Maclnnes, solicitors for the Company. ...

In arriving at my decision, notwithstanding my opinion that the Board is in no way bound by the Department of National Revenue’s Interpretation Bulletins, I have taken judicial notice of its Interpretation Bulletin IT-269, which reads in part as follows:.. » Non-capital losses for purposes of paragraph 186(1)(d) include business losses for years prior to 1972 that are deemed to be non-capital losses by subsection 37(1) of the ITAR, provided the corporation qualified as a private corporation pursuant to paragraph 89(1)(f) for such prior years. ...

Again in a case under another provision of this very sec 6 (sec 5(1)(a)—Ed) where a discretion to fix the amount to be allowed for depreciation is given to the Minister, Lord Thankerton in delivering the judgment of the Board said “The Minister has a duty to fix a reasonable amount in respect of that allowance and, so far from the decision of the Minister being purely administrative and final, a right of appeal is conferred on a dissatisfied taxpayer; but it is equally clear that the Court would not interfere with the decision unless—as Davis, J states —'it was manifestly against sound and fundamental principles’ ”. ...

It is said to be dated November 25, 1966 and reads as follows: Mr Frank Selby Greyhound Lines (Canada) Ltd 712 Greyhound Building Calgary, Alberta Confidential & Restricted Dear Mr Selby: As discussed in our meeting today the following space in the Greyhound Building is now rented by the AMR group. 1. ...

Mr Justice Cattanach in the appeal MNR v Howson & Howson Limited et al, [1970] CTC 36 at 51; 70 DTC 6055 at 6063 stated: However, the fact that the four foregoing reasons may well have been reasons that entered into the decision to create separate entities does not dispose of the critical issue upon which the present appeals turn which is whether one of the main reasons for doing so was the consequent tax reduction. ...

I think this is clearly a case of the agreement being an agreement penned in one sense, to be read in another, which is really a paraphrasing of the classical definition of “sham” in the Snook v London & West Riding Investments Ltd, [1967] 1 All ER 518 at 528. ...

Examples: Doris Trucking Company Limited v MNR, [1968] 2 Ex CR 501; [1968] CTC 303; 68 DTC 5204; MNR v Howson & Howson Company Ltd, [1970] CTC 36; 70 DTC 6055; Alpine Furniture Company Limited v MNR, [1969] 1 Ex CR 307; [1968] CTC 532; 68 DTC 5338. ...