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The Board’s decision was followed recently by this Court in Granby Construction & Equipment Ltd. v. ...

In this connection, counsel for the Respondent commented as follows in his memorandum submitted during oral argument entitled “Respondent’s Points of Argument”: At the time of amendment of the provision into its present form 1956, the Minister responsible indicated that the deduction was not intended to be applicable in the case of all clergymen or ministers, and that it was to apply to a clergyman, ‘whether he be in fact a pastor in charge of a congregation or a member of the church body in the higher level [...] who engages in church work exclusively including acting as a pastor from time to time’. ...

By notices of reassessment, the Minister added the following four amounts as “additional initiation fee income” to the Appellant’s reported income for the four respective taxation years shown below: Taxation Year Amount December 31, 1992 $696,860 December 31, 1993 $335,003 February 18, 1994 $ 71,736 October 31, 1994 $132,693 The amount of $696,860 in the above table was calculated as follows: Initiation fees received in 1992 $357,210 Add initiation fees deferred from prior years 441,154 Subtotal 798,364 Less initiation fees reported as part of net income for 1992 101,504 Additional initiation fee income $696,860 The Appellant claims in paragraph 5 of its Amended Notice of Appeal that, if it does not provide continuous access to and use of its club facilities to a particular member over a ten-year period commencing on the date of initial membership, it is obliged to refund a pro rata portion of the initiation fee which relates to the portion of the 10-year period during which its facilities are not provided to the particular member. ...

On subscription each investor was required: a) to contribute $105,000 per unit by means of financing arranged for the investor (“Note A”) b) to make a cash payment of $10,925: c) to execute promissory notes (Notes “B” and “C” in the principal amounts, respectively of $35,000 and $31,000 — totalling $66,000) less the cash payment of $10,925. ...

In filing her income tax return for the 1994 taxation year, the Appellant reported total income before deductions in the amount of $183,840, calculated as follows: Employment Income $ 65,000 Interest and other investment income 28,840 Business Income 90,000 $183,840 The business income of $90,000 represented a management fee paid to the Appellant by Holdings. ...

Year Income Losses 1990 0 $57,283.29 199] $1 1,793.38 $71,103.00 1992 $12,275.22 $53,607.78 1993 $43,705.56 $58,319.64 1994 $ 7,347.47 $36,715.55 1995 $21,722.90 $27,067.95 1996 $1 1,594.24 $21,312.68 In 1995 Mr. ...

It was established that losses and relevant figures were as follows: Taxation Year Gross Income Expenses Net Income (Loss) 1988 nil $17,719 ($17,719) 1989 $15,144 $43,821 ($28,377) 1990 $22,973 $64,109 ($41,136) 1991 $ 7,227 $39,232 ($32,005) 1992 nil $60,927 ($60,927) 1993 nil $51,450 ($51,450) The Appellant was also asked questions, on cross-examination on two occasions, respecting why he did not get rid of the boat. ...

Pursuant to paragraph 7 of the agreement, the appellant had no control over any amendment to the terms and conditions of the mortgage provided Clarfield agreed to any change sought by Gooden and participants representing at least 51 % interest in the loan to Gooden also agreed that such change, alteration, modification or variation be made. ...

At the same time, Budney requested the appellant to participate in a business corporation known as Affordable Tire & Auto Repair Ltd. ...

At 11 % interest, an increased expense of $6,600 is very close to the loss reported in each of the three years. ...