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The day following receipt of the reassessments Harris attended at the offices of his accountants Meyers, Norris, Penny & Co where, following a consultation with a senior partner, he was referred to Mr N F Cochrane (Cochrane). ...

Attached to the letter is a single sheet of paper entitled “Appraisal for Parkland Savings & Credit Union”. ...

Section 149(1)(1) of the taxation years in issue read as follows: 149 (1) No tax is payable under this Part upon the taxable income of a person for a period when that person was (1) a club, society or association that, in the opinion of the Minister, was not a charity within the meaning assigned by subsection 149.1(1) and that was organized and operated exclusively for social welfare, civic improvement, pleasure or recreation or for any other purpose except profit, no part of the income of which was payable to, or was otherwise available for the personal benefit of, any proprietor, member or shareholder thereof unless the proprietor, member or shareholder was a club, society or association the primary purpose and function of which was the promotion of amateur athletics in Canada; Section 149(5) provides as follows: (5) Notwithstanding subsections (1) and (2) where a club, society or association was for any period, a club, society or association described in paragraph (1)(1) the main purpose of which was to provide dining, recreational or sporting facilities for its members (in this subsection referred to as the “club”), an inter vivos trust shall be deemed to have been created on the later of the commencement of the period and the end of 1971 and to have continued in existence throughout the period; and, throughout that period, the following rules apply; [Emphasis mine] Both of these sections come under “Division (H) — Exemptions” of the Income Tax Act and the relevant words upon which the Minister relies are contained in section 149(5) and read as follows:... the main purpose of which was to provide dining, recreation or sporting facilities for its members (in the subsection referred to as the “club”) The Association has no proprietary interest or authority over any of the individual curling clubs or its members. ...

Rossburn and Kings — Developers, Architects and Engineers were approached but negotiations were not proceeded with because it is alleged Rossburn and Kings wanted to purchase the property outright. ...

In Collins v Joseph Adamson & Co, [1938] 1 KB 477, Lawrence, J stated the position as follows: If the money is spent for the purposes of the trade, and the expenditure would, if successful, produce either a capital asset or an asset of an enduring nature, or an advantage of an enduring nature, which is of a capital nature, it is equally a capital payment if the expenditure is unsuccessful. ...

.: — This appeal was heard in Vancouver, British Columbia, on September 25, 1996, under the Informal Procedure. ...

This decision has also been examined by other judges of this Court, for example, Judge Dussault in Samson & Frères Ltée v. ...

.: — The appeals of David Green (the Appellant) are from reassessments of income tax made in respect of his 1991 and 1992 taxation years. ...

.: — On April 17, 1996 I signed the reasons for judgment and the judgment pertaining to these appeals. ...

.: — This is an appeal from a Notice of Reassessment issued on March 11, 1994, by the Minister of National Revenue (the “Minister”) and bearing number 3816937 in respect of the taxation year ended May 31, 1989, of Cargill Grain Company Limited. ...