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He became connected in 1956 with the real estate firm in Toronto known an Mann & Martel. ... Another activity of Townsview was the acquisition of buildings to be used as offices for Mann & Martel. ... Correspondence passed between him and Mr Orenstein and it appeared from meetings with Mr Orenstein and Mr Hamann, an architect of the firm Bregman & Hamann, that matters were moving forward. ...

On his income tax return, opposite this item, appears the words ‘‘Moving expenses 1974 ($38,729.35 + 213.92) carrying charges Sched 4D ($213.92) See attached Notice of Assessment 1974 Income Tax.” ... Counsel specifically pointed out a phrase in Mr Justice Addy’s reasons: “.... and certain other very specific expenses relating directly to the actual move.. and submitted as an example, it could be that storage charges (see paragraph 62(3)(b)) would not have been a moving expense had they not been specifically included in that paragraph. ... As to what is deductible, subsection 62(1) contains the words “..,. there may be deducted amounts paid by him...”. ...

The appellant, a real estate broker for Irwin, Sargent & Lowes Limited, the son of Roy Irwin, a shareholder of the said firm, entered into an agreement dated May 1, 1972, to purchase his father’s 166% common shares in the firm for $109,697. The agreement (Exhibit A-1) provided that the payment of $109,697 by the appellant would be made from the profits accruing from his shares in Irwin, Sargent & Lowes Limited and paid directly: by the firm to the appellant’s father. ... Inland Revenue Commissioners v Port of London Authority, [1923] AC 507; Inland Revenue Commissioners v Rowntree & Co Ltd, [1948] 1 All ER 482; Dupuis Frères Ltd v Minister of Customs. and Excise, [1927] Ex CR 207; [1917-27] CTC 326; 1920-1940 DTC 104. ...

Doctrine Phipson on Evidence, 12th edition; Sopinka & Lederman: Evidence in Civil Cases. 4.03 Analysis 4.03.1 In his argument, counsel for Cyril Stern said that all the letters between counsel for the parties written from 1972 to 1974 must not be considered because of the following rule of law quoted from Sopinka & Lederman, Evidence in Civil Cases: By the general rules of the common law, if there be a contract which has been reduced into writing, verbal evidence is not allowed to be given of what passed between the parties, either before the written instrument was made, or during the time that it was in a state of preparation, so as to add to or subtract from, or in any manner to vary or qualify the written contract... ...

Harvey Clark Smith v MNR, [1960] CTC 391; 60 DTC 1282 — in this case the appellant was a farmer and the appeal was dismissed. ... Rosslynn Estates Limited v MNR, [1972] CTC 65; 72 DTC 6051 — the appeal was dismissed because the income derived from land for agricultural purposes did not justify its purchase as a revenue-producing investment and the justification for the purchase by a company incorporated to deal in land could only be found on the prospect of a future sale at profit. ...

The vendor of the above-mentioned equipment was Finning Tractor & Equipment Company Limited. ... Therefore, he suggests that the income between January and July was his own income — or January to May, actually. ...

The argument that the appellant had extensive experience in the real estate field and that he had knowledge of the shopping centre project — and was even in possession of a verbal offer to purchase from Les Immeubles Carrefour Ltée — is pure conjecture and is not, in my opinion, supported in any way by the evidence. ...

Law — Analysis 4.01 Law The main legal provisions involved concerning the employment tax credit program for that year are paragraph 12(1)(q) and subsections 127(13) and 127(16) of the Income Tax Act, SC 1970-71-72, c 63, as amended, and section 6000 of the Income Tax Regulations. ... In these Regulations, “normal work force” means (a) in the case of an employer providing employment in any business where, at the place of employment during the fifty-two week period imediately preceding the first date on which the employer entered into an agreement with the Minister, (i) there was a week for which ten or more employees were each paid wages for fifteen or more hours of work in that week, and (ii) the highest number of employees who were each paid wages for fifteen or more hours of work in any week during that period exceeded by more than 33 / per cent the lowest number of employees who were each paid wages for fifteen or more hours of work in any other week during that fifty- two week period, the number of employees at the place of employment who were on the payroll of the employer and were each paid wages for fifteen or more hours of work during the corresponding week in the preceding year,... 5. ...

Counsel for the appellant also likened this appeal to the case of Her Majesty The Queen v V & R Enterprises Limited, [1979] CTC 465; 79 DTC 5399, another case which supposedly involved the question of an accrued bonus. ... Counsel also referred to the V & R Enterprises Limited case, but the reasons of Mr Cardin, Chairman of this Board, purely to indicate what, at least in Mr Cardin’s view, was the criteria to be met in the case of accrued bonuses. ...

Mr Siddons enquired of Dye & Durham Co Limited which had printed the form and was advised that the form used (Exhibit A-1) was not printed until November 16, 1970 and could not therefore have been signed on April 1, 1970 (Exhibit R-2). ... Mr Henri St-Jacques, a lawyer from the firm of St-Jacques & St-Jacques who drafted the purchase and sale agreement, on being shown Exhibit A-1, could not recall when he received instructions to draft the agreement or when the document was signed. ...