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It was suggested that the income received from the disposition of the lots arose as a result of the appellant’s earlier activities — as an active development company — there being no need of further activity with respect to the income receivable from the subsequent sale of the lots, the appellant then became a non-active company. ...

The position of the respondent was a requirement that the appellant submit proof that: —funds in the amount of the deduction claimed were in fact remitted to those people; — his father, stepsisters, and brother-in-law were dependent upon him within the meaning of that word as used in the Income Tax Act. ...

(b) Les Placements du Moulin Ltée: Fernand Perron 33%% Georges-Henri Perron 3313% André Perron 3313% (c) Les Immeubles Perron Ltée: Mrs J-Euclide Perron (mother) 2% Madeleine Perron \ These five persons are the Colette Perron I daughters of Mrs J-Euclide Monique Perron > Perron and the sisters 49% Michèle Perron (of Fernand, Georges-Henri Thérèse Perron / and André Perron. Les Placements du Moulin Ltée 49% 100% (d) Mars Finance Inc: The three Perron brothers 16.21% Georges-Henri Perron’s children 0.33% The five Perron sisters 3.04% J-Euclide Perron Ltée 20.21% Les Placements du Moulin Ltée 1.76% Les Immeubles Perron Ltée 10.32% Outsiders 48.13% 100 % 3.2 In 1972 and 1973 the percentages shown above did not vary enough to affect the principle involved, so that the above figures serve as a basis for ruling on the assessments for 1972 and 1973 also. 3.3 For 1971 each appellant company is applying to have the first $35,000 of income taxed at a rate of 18% instead of 51%: for 1972 and 1973 they are seeking to have the first $50,000 of income taxed at 25% instead of 50% (1972) and 49% (1973), the whole in accordance with subsection 39(2) of the Act (RSC 1952, c 148 as amended) and section 125 of the Act (SC 1970-71-72, c 63 as amended). 4. ...

NC, (BMS), pursuant to which LINETT is or will be authorized to collect or make collections with respect to any of the following debits: FRANCHISE DEBIT NUMBERS Home Reader Service of Montreal #560A & #560J Civic Reading Club of Montreal #591 A, #591J & #594J Civic Reading Club of London #481A & #481J Home Reader Service of Quebec #615A Mutual Readers League of Montreal #214A Civic Reading Club of London #507B Civic Reading Club of Montreal #590C Home Reader Service of Toronto #660B The deductions from the commission referred to above shall be in an amount equal to three percent (3%) of LINETT’S gross collections made on the above debits and may be deducted in any manner permitted by any Collection Agreements between LINETT and HRS or between LINETT and BMS, including, but not limited to, payment directly to HRS or to BMS on behalf of HRS out of any qualified bank account into which collections are deposited by LINETT. ...

For the respondent: —Atlas advanced monies on behalf of the appellant by the year ended November 30, 1976 in the following amounts: January 19,1976 $ 3,288.60 April 8,1976 6,577.20 August 20,1976 55,906.20 $65,772.00 —The letter dated January 11, 1977 and the promissory note dated November 2, 1977 did not constitute a “bona fide arrangement” and neither were such arrangements “made at the time the loan was made”; —The letter dated January 11, 1977 and the promissory note dated November 2, 1977 did not constitute “repayment thereof within a reasonable time”. ... The letter and the note read as follows: January 11, 1977 Willetts Macmahon & Company 1901 Toronto Dominion Tower Edmonton Centre Edmonton, Alberta T5J 2Z1 Dear Sirs: This letter is to confirm that Atlas Electrical Supply Ltd has advanced funds to me for the purpose of purchasing a dwelling for my own occupation. ...

His evidence was that the appellant also has substantial interest in Crown Glass & Mirror Ltd which was more successful and continues to be operated by the appellant’s two sons. ... He had financial statements made for his meat business and Crown Glass & Mirror Ltd business, and reported their profit and loss in his tax returns. ...

The appellant performed such work during 1978 as an employee of Coopers & Lybrand, a firm of chartered accountants. ... It is plain that authorized payments were insufficient to meet operating expenses, both as a result of insufficiency of the mileage rate paid by Coopers & Lybrand and as a result of limitations imposed by that firm on the circumstances in which it was prepared to pay mileage expenses to its employees. ...

The appeals were called at the time and place set forth in the Notices of Hearing — April 13, 1982 at Toronto. ... The Board granted the adjournment although counsel for the Minister objected strongly, reciting as reasons for objecting — the waste of time in preparing for the case, similar effort would have to be expended again in two or three months, and the costs already incurred. ...

In reassessing the Appellant in respect of his 1980 taxation year and thereby disallowing the deduction of $150 paid to the Appraisal Institute of Canada, the Respondent proceeded on the basis that the amount so paid was not one which “... Was necessary to maintain a professional status recognized by statute” since: (a) the Province of Ontario does not have legislation which recognizes a real estate appraiser as having a professional status, (b) the payment made was not necessary to maintain a professional status, and (c) the payment of such amount was not one required to be made to maintain the Appellant’s employment with the Department of Nation Revenue — Taxation. ...

That has been put in the form of a direct challenge — not a basis for decision which I relish in general, but neither is it one from which I may abstain. ... There was a discussion between counsel and the Board at the commencement of this adjourned part of the hearing with regard to the particular nature of subsection 152(4) and subsection 152(5) of the Income Tax Act — whether or not, in effect, the order of the Board as has just been read put those issues to rest (the amounts of $6,229.97 and $48,931.03) and left them beyond any further discussion. ...