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In so assessing the Minister of National Revenue disallowed expenses claimed in the following amounts: 1975 — $3,521.31; 1976 — $9,268.59; 1977 — $9,116.03. ... Artistic production — including writings, musical, dramatic and cinematographic works. ... Every relationship, whether “employment” or “business”, is founded on some form of contract — written, oral, explicit or implied — and it is to the terms of the contracts available in this matter that the Board must look for guidance. ...

Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act, SC 1970-71-72, Chapter 63 as amended, involved in the present case are 150(1)(a), 162(1), 186(1) as passed before the amendment of December 6, 1979, the amendment to subsection 186(1) found at subsections 56(1) and (2) of 28 Eliz Il, Chapter 5, and subsections 187(1), (2) and (3). ... Cable Mines <& Oils Limited v MNR, 28 Tax ABC 42; 61 DTC 641; 3. ... Is it correct to refuse to pay interest charged from March 31, 1979 (“... the last day of the third month after the end of the year...” subsection 186(1) introductory paragraph) by the respondent? ...

The appellant owned all the shares of William Scott & Company Limited of Vancouver, British Columbia and Centennial Hatcheries & Breeding Farms Limited of Hammond, British Columbia, which companies were involved in the poultry-raising business and were managed by the appellant, for which the appellant received a management fee. ...

At page 91 Mr Justice Mignault states the following:.. » Many factors undoubtedly influence the market price of shares in financial or commercial companies, not the least potent of which is what may be called the investment value created by the fact / or the prospect as it then exists / of large returns by way of dividends, and the likelihood of their continuance or increase, or again by the feeling of security induced by the financial strength or the prudent management of a company. ...

In the agreement of sale $30,000 was allocated to the value of the land and $173,000 to the value of the building (Schedule C — Exhibit A-2). ... Sterilization or spraying the processing sections of the plant with chlorine or iodine solutions — as indeed was done at one point by the appellant — causes the destruction of the bacteria linens and indeed all bacteria and makes the processing of good quality limburger or brine cured brick cheese impossible. ... The difference between the expected earnings from the plant with bacteria present as opposed to earnings without the bacteria — when no earnings would be realized but losses incurred — provides, Dr Finlay suggests, an estimate of the economic value of bacteria in a cheese plant. ...

Telephone $ 12.00 2. Travel I i ng expenses 93.00 3. Rent expense 419.00 4. Heat, Light & Power 66.00 5. Professional dues 20.00 6. Periodicals & Books 100.00 7. ...

The Board finds little reason to refer to the specifics of the amounts at issue, both parties having been in accord, but does note that the sections of the Act in dispute refer to section 125 and Regulation 5202 — essentially, the manufacutring and processing credit that is available to Canadian corporations. ... The critical portion of the Act is in section 5202 of the Regulations — the definition of “cost of manufacturing and processing capital” — and it reads for the record: “cost of manufacturing and processing capital” of a corporation for a taxation year means 100/85 of that portion of the cost of capital of the corporation for that year that reflects the extent to which each property included in the calculation thereof was used directly in qualified activities of the corporation during the year, but the amount so calculated shall not exceed the cost of capital of the corporation for the year. ... The Act does not say “required for use in qualified activities”, which is the basis of the appellant’s argument — the Act says specifically “used directly in qualified activities”. ...

The appellant submitted that: — Work in progress is not income in these circumstances; — Section 36 of the Judges’ Act prohibits and forbids a judge from engaging in any business or occupation other than his judicial duties. In assessing the appellant, the respondent relied inter alia, upon sections 3, 9 and 34 of the Income Tax Act SC 1970-71-72, c 63, as amended, and contended that: — the amount of $35,183.38 became receivable by virtue of of paragraph 34(1)(c) of the Income Tax Act during the appellant’s 1974 taxation year and was properly included by virtue of paragraph 34(1)(b) of the Income Tax Act in computing the appellant’s income from a business that was a profession for his 1974 taxation year. ... The perception that subsection 28(5) is applicable to the present case (a profession) is strengthened by a review of the predecessor section in the Old Act — 85F(4) which is identical to the current subsection 28(5). ...

Mr Lund tried to comply with their requirements and prepared a new set of plans — again in respect of a 108-suite apartment building. ... According to the evidence adduced, most of the relevant allegations of the respondent were proven — which is more than enough to dismiss the appeal. ... On the other hand, both Mr Lund and Mr Goddard had some experience in real estate transactions — especially Mr Goddard who was an experienced real estate agent. ...

Act — Case Law — Comments 4.01 Act The principal section of the Income Tax Act involved in this case is section 8. ...