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That ruling required “... that franchise fee revenue from individual and area franchise sales be recognized only when all material services or conditions relating to the sale have been substantially performed or satisfied by the franchisor”. ... For the foregoing reasons I am unable to find that any part of the $92,795 is an amount “... described in paragraph 12(1)(a)...” of the Act. ...

The second paragraph of the preamble of the agreement reads as follows: (Document #1 — appellant’s brief) AND WHEREAS it is contemplated that at the time of closing (as hereinafter defined) the issued capital of the Company will consist of 10,001 common shares (the “Purchased Shares”) all of which shall be beneficially owned by the Vendor. ... The contracting parties also provided for the termination of the agreement by either the purchaser or vendor if any of the stipulated conditions were not fulfilled (Clause 7, Document #1 — appellant’s brief). ...

The items and the amounts in issue in these appeals can be summarized as follows: 1973 Expenses Claimed Allowed Disallowed Automobile $3,693.34 $3,165.89 $ 527.45 Public Phone 260.00 100.00 160.00 Office in Home 903-85 47-26 06-59 Entertainment 3,808.76 1,999.15 1,809.61 Interest Expenses Claimed Allowed Disallowed Canadian Imperial Bank of Commerce 1,881.37 0 1,881.37 Carrying Charges Claimed Allowed Disallowed Toronto Dominion Bank $1,019.00 0 $1,019.00 John Harris Farms 1,500.00 0 1,500.00 Flying Dutchman Motel 500.00 0 500.00 Travel Expenses Hawaii 3,223.54 0 3,223.54 Grubstaking expenses 3,245.84 0 3,245.84 1974 Expenses Claimed Allowed Disallowed Automobile $3,272.19 $2,843.62 $ 428.57 Public Phone 260.00 100.00 160.00 Office in Home-840774 923-44 603-70 Entertainment 3,096.85 2,315.18 781.67 Interest Expenses Claimed Allowed Disallowed Canadian Imperial Bank of Commerce 2,289.94 0 2,289.94 Carrying Charges Claimed Allowed Disallowed Toronto Dominion Bank $3,178.87 0 $3,178.87 John Harris Farms 4,000.00 0 4,000.00 Flying Dutchman Motel 500.00 0 500.00 Travel Expenses Grenada 624.58 0 624.58 Grubstaking mining expenses 18,149.95 0 18,149.95 Counsel for the respondent conceded that, based on evidence presented, an expenditure of $260 for pay-phone for each of the 1973 and 1974 taxation years might possibly be considered as a reasonable business expense. ...

Montreal Coke & Manufacturing Co v MNR, [1944] CTC 94; 2 DTC 535; 5. ... The same comments may be made mutatis mutandis concerning Montreal Coke & Manufacturing Co, [supra] in which the year involved was 1935. ...

IRC v Fleming & Co Ltd, 33 TC 57; 9. Van den Berghs Ltd v Clark, [1935] AC 431; 10. Barr, Crombie & Co Ltd v IRC, [1945] SC 271; 11. Short Brothers Ltd v IRC, 12 TC 955; 12. ...

Et puis il a référé la Commission à de nombreuses décisions qu’il a divisées en deux catégories: Décisions favorables à l’intimé: William Richard Kay c MRN, [1971] Tax ABC 363; 71 DTC 285; Morley M Reider c MRN, [1970] Tax ABC 1178; 70 DTC 1746; Fox & Walker Ltd c MRN, [1969] Tax ABC 483; 69 DTC 388; Hugh Knox Ltd c MRN, [1973] CTC 2053; 73 DTC 50; Bainbridge Agency Ltd c MRN, [1971] CTC 878; 71 DTC 592; Vincent Doriste Moreau c MRN, Ex CR 198; [1977] CTC 2249; 77 DTC 153; Silverwood Dairies Ltd c MRN, 38 Tax ABC 379; 65 DTC 445; D Dupéré Inc c MRN, [1960] Tax ABC 198; 60 DTC 560. Décisions défavorables à l’intimé Francis David Moyls c MRN [1966] Tax ABC 411; 66 DTC 553; Halliday Fuels Ltd c MRN, [1960] Tax ABC 186; 60 DTC 541; Harbord Investment Ltd c MRN, [1970] Tax ABC 717; 70 DTC 1488; Simon Voyer <& Castelli Inc c MRN en appel. ...

The Facts 3.01 The appellant, as purchaser, entered into an agreement for sale dated September 17, 1975 with Mr Frank Remai and Mr Joseph Remai. 3.02 This agreement (Exhibit A-1) reads as follows: BETWEEN: FRANK REMAI and JOSEPH REMAI, both of Saskatoon, in the Province of Saskatchewan, to each an undivided one-half interest, — hereinafter called the Vendor OF THE FIRST PART, and WILLIAM SCHULTZ, of the City of Saskatoon, in the Province of Saskatchewan, —hereinafter called the Purchaser OF THE SECOND PART. ... A receipt was also produced as Exhibit A-3 in the amount of $10,000 signed by Remai Construction Company (1971) Ltd with reference: “Landscaping payment—3170 & 3176 Laurier St”. ...

Both witnesses had, by their company, Pearce, Kennedy & Associates Ltd, carried on the business of business valuators and brokers for a period of 14 months. ... A summary of the results which they arrived at is as follows: Summary of Share Valuation Estimated Value of the LPG Sales Division $1,350,000 Add: redundant assets —estimated value of the resource properties $1,969,439 —estimated value of the underground storage facilities 180,000 2,149,439 Less: allowance for tax costs @ 15% 322,416 1,827,023 Estimated fair market value of 2,339,402 shares $3,177,023 per share $1.36 say $1.40 This value of $1.40 per share is certainly realistic in view of the fact that the stock market price had risen to $1.65 per share in June, 1972. ...

In its 1975 fiscal year it loaned $79,000 to Yankel Ranch & Development Ltd (hereinafter called “Yankel”). ... The following advances were made to Yankel: $ 4,000 August, 1974 $35,000 September, 1974 $40,000 September, 1974 In each case the appellant received interest-bearing promissory notes. ...

For the respondent, the following assertions were made: —The appellant was not ordinarily required to carry on the duties of his employment away from his employer’s place of business or in different places; — Under the contract of employment, the appellant was not required to pay for the expenses incurred in the performance of the duties of his employment; —The appellant was reimbursed for all expenses incurred in performance of the duties of his employment; — During the relevant years, the appellant was in receipt of a travel allowance of 12¢ per mile in 1973 and from 15¢ to 18$ in 1974 to cover his automobile expenses: —Upon submission of vouchers the appellant was reimbursed all expenses other than those mentioned in the precedent subparagraph incurred in the performance of his duties; —The automobile expense which the appellant claims to deduct in computing his income for the relevant years are not reasonable and constitute personal and living expenses of the appellant. ...