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The proceeds of disposition received by Appellant was $112,000 which was allocated as follows: $ 10,838.23 Land $101,161.77 Building 7. ...

Minister of National Revenue, [1978] CTC 2076, 78 DTC 1097 A W Prociuk (orally: November 15, 1977):—The appellant, Vincenzo Curcio, appeals from the respondent’s reassessment of his income for the taxation years 1967 to 1972 inclusive, on a net worth basis wherein the following amounts of unreported income were added in each taxation year and taxed accordingly: 1967 $5,108.86 1968 $5,397.41 1969 $9,055.35 1970 $2,778.37 1971 $3,925.88 1972 $5,199.23 The appellant was also assessed for penalties pursuant to subsection (2) of section 56 of the Income Tax Act, RSC 1952, c 148, and Subsection (2) of section 163 of the Income Tax Act, SC 1970-71-72, c 63, and section 17 of The Income Tax Act of the Province of Ontario as follows: Canada Ontario 1967 $199.32 $ 59.58 1968 227.93 66.56 1969 440.67 134.34 1970 127.12 32.33 1971 188.29 49.96 1972 286.09 100.19 The appellant was also assessed a late filing penalty for the taxation year 1972 in the sum of $106.76 but at the commencement of the hearing of this appeal counsel for the appellant advised that this portion of the appeal is being abandoned. ...

Counsel for the respondent cited a number of precedents: G H Chambers (Northiam Farms) Ltd v Watmough (HM Inspector of Taxes), 36 TC 711; Niessen v MNR, 25 Tax ABC 62; 60 DTC 489; No 485 v MNR, 18 Tax ABC 358; 58 DTC 69: Zakoor v MNR, 35 Tax ABC 338; 64 DTC 392: W J Kent & Co Ltd v MNR, [1971] Tax ABC 1158; 72 DTC 1018. ...

Alfred David Perry, dept, of Northern Affairs & National Resources, p.o. ...

On August 21, 1970 we authorized a loan of $52,000, funds from which were utilized for investment in F H Deacon & Co Ltd, Rampart Securities Ltd and Cerro Corp. ...

In other words, in that case the structures or the assets outside the mill became part of the mill — became part of the building. ...

The question to be determined, therefore, is whether or not the appellant was carrying on a business — and, indeed, whether what is commonly known as “playing the stock market” can be considered to be a business within the meaning of the definition contained in subsection 248(1) of the Income Tax Act. ...

In Her Majesty the Queen v Morton Pascoe, [1975] CTC 656; 75 DTC 5427, a recent Federal Court of Appeal case cited by counsel for the respondent, Pratte, J, on page 658 [5428], defined “alimony or other allowance” as follows:. ». ...

Here follows a list of gifts made to the said daughters showing at the same time the taxable income of the deceased in the relevant years (the gifts shown in the aggregate amounts): Year Amount of Gift Taxable Income 1954 $ 2,500 $35,400 1955 2,000 32,500 1956 2,000 32,600 1957 4,000 33,500 1958 4,000 47,800 1959 4,000 54,100 1960 4,000 50,600 1961 4,000 54,000 1962 4,000 52,500 1963 4,000 54,600 1964 4,000 54,400 1965 4,000 54,800 1966 20,000 61,900 1967 21,000 23,900 In assessing the estate for estate tax purposes the Minister of National Revenue has, pursuant to paragraph 3(1)(c) of the Estate Tax Act, included in the estate the gifts shown above as being made in the years 1965, 1966 and 1967 and has allowed a deduction of $4,000 under paragraph 7(1)(e) of the Estate Tax Act. ...

(signed) Robert Bastien Robert BASTIEN, economist, MBA Executive Vice-President SAPF Expert in tax reduction. ” Although it was purely hypothetical for the appellant, these advertising tactics impressed him sufficiently for him to commit himself to investing $5,000 in order to receive a capital cost allowance of $19,030. ...