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The financial results of 1966 to 1973, as submitted by the respondent, and not contradicted by counsel for the appellant, were as follows: Sa/es Sales Expenditures Losses in book business 1966 $4,872.24 $17,417.77 $12,545.53 1967 $2,308.92 $ 7,402.34 $ 5,093.42 1968 $4,150.10 $12,392.26 $ 8,242.16 1969 $8,428.46 $17,813.55 $ 9,385.09 1970 $3,427.24 $12,871.40 $ 9,444.16 1971 $6,723.02 $17,417.14 $10.694.12 1972 $2,822.90 $12,740.21 $ 9,918.31 1973 $ 734.16 $ 9,653.13 $ 8,918.97 3.8. ... The following is the appellant’s statement of income and expenditure for 1971, given as a typical example of the various expenditures which explained the appellant’s losses with regard to the publication and sale of his books: Net sale of books $ 6,723.82 Harpell Press: purchase of books $ 3,475.00 New York Times: advertising $ 6,260.50 Book World: advertising $ 1,415.63 Consumption [sic] of books $ 78.65 Printing of circulars $ 289.18 Clerical costs $ 3,000.00 A&C annuities and pensions, illness $ 99.72 Travel: book business $ 3,059.68 Bank charters $ 21.96 Nat photoengraving, text illustration S 419.71 C Podlone: text revision $ 360.00 Stationery $ 348.60 Bell Tel $ 31.38 Burnett, Appleby: purchase of names $ 225.40 Postage $ 943.53 $20,028.94 Increase in inventory $ 2,611.00 $17,417.94 Losses of book business $10,694.12 This statement of income for 1971 was admitted by the respondent as being representative of the other years concerned. 3.14. ...

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Ivesleigh Holdings Inc, Fontaine, Bilodeau & Cie Ltée, Baribeau & Fils Inc, Jeviam Inc v. Minister of National Revenue, [1978] CTC 2984 Roland St-Onge [TRANSLATION]:—The appeals of Ivesleigh Holdings Inc, Fontaine, Bilodeau & Cie Ltée, Baribeau & Fils Inc and Jevlam Inc were heard by me on September 16, 1977 in Quebec City, Quebec. ... For this purpose we Prepared the following tables for all the public companies which, according to our information, are operating in the broadcasting field: — price/earnings ratio for the principal radio and television broadcasting companies on December 31, 1971, including certain data on Télé-Capitale Limitée; — analysis by sector of operation of the principal radio and television broadcasting companies, including Télé-Capitale Ltée, in 1971; — percentage distribution of the gross revenue of the:companies, including Tele-Capitale Ltée, by sector of operation for 1970 and 1971. ...

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Roger Mercure■ ' I v. Minister of National Revenue, [1978] CTC 2215, 78 DTC 1165 Guy Tremblay [TRANSLATION]:—The case at bar was heard at Montreal, Quebec on June 9, 1977. 1. ... The following are the expenses which were disallowed, as they appear on the tax returns: 1971 1972 1972 1973 1973 Entertainment allowance $ 835.20 $1,235.20 $4,785.00 Business taxes $ 108.00 Automobile expenses $2,775.20 $6,900.00 Fire insurance $ 244.00 $ 485.00 Office expenses $ 265.00 Telephone $ 85.00 Travel expenses $1,325.00 $3,854.40 $8,620.20 $6,568.00 Less: 25% personal use $ 963.60 $2,155.05 $2,890.80 $6,465.15 $6,568.00 3./. ...

In those reassessments, the Minister levied the following federal penalties: Taxation Date of Year (Re)Assessment Penalties 1971 24 November 1977 $ 80.75 3 March 1978 $1,481.96 24 May 1979 $ 100.83 1972 24 November 1977 $ 631.23 3 March 1978 $ 822.83 24 May 1979 $ 643.85 1973 24 November 1977 $2,789.09 3 March 1978 $4,451.77 24 May 1979 $2,948.87 1974 24 November 1977 $2,570.56 3 March 1978 $3,460.75 24 May 1979 $2,681.11 1975 24 November 1977 $ 543.08 3 March 1978 $ 970.01 24 May 1979 $ 580.19 (k) The Appellant appropriated to his own benefit unreported revenue of MidNorth in the amounts of $2,807.41, $11,573.36, $18,402.72 and $900 respectively in his 1972, 1973, 1974 and 1975 taxation years. ... The same two persons (/ and plus Alan Hill (were partners in NIM Disposals. ... March 12 1973 5815 $ 1,229.30 BG; BL 2. March 26 1973 5861 2,000.00 BG; BL 3. ...

The said application reads as follows: IN RE the Application under Section 174 of the Income Tax Act Between: CAVERHILL, LEARMONT & CO LIMITED, Appellant, — and — THE MINISTER OF NATIONAL REVENUE, Respondent, — and — CANADIAN HORTICULTURAL INDUSTRIES, Third Party. ... B) THE TAXPAYERS THAT THE RESPONDENT SEEKS TO HAVE BOUND BY THE DETERMINATION OF THE QUESTION ARE: — CAVERHILL, LEARMONT & CO LIMITED — CANADIAN HORTICULTURAL INDUSTRIES C) STATEMENT OF FACTS AND REASONS: 1. ... Horticultural Industries having participated in a common transaction with Caverhill, Learmont & Co Limited, an appellant before this Board, the Board orders that Canadian Horticultural Industries be joined to the appeal of Caverhill, Learmont & Co Limited. ...

The said application reads as follows: IN RE the Application under Section 174 of the Income Tax Act Between: CAVERHILL, LEARMONT & CO LIMITED, Appellant, — and — THE MINISTER OF NATIONAL REVENUE, Respondent, — and — CANADIAN HORTICULTURAL INDUSTRIES, Third Party. ... B) THE TAXPAYERS THAT THE RESPONDENT SEEKS TO HAVE BOUND BY THE DETERMINATION OF THE QUESTION ARE: — CAVERHILL, LEARMONT & CO LIMITED — CANADIAN HORTICULTURAL INDUSTRIES C) STATEMENT OF FACTS AND REASONS: 1. ... Horticultural Industries having participated in a common transaction with Caverhill, Learmont & Co Limited, an appellant before this Board, the Board orders that Canadian Horticultural Industries be joined to the appeal of Caverhill, Learmont & Co Limited. ...

For the various financial years of the company ending on January 31 and for the financial years of the appellant shareholder, the expenses in dispute are given below: Appellant company Appellant shareholder 1966 $ 1,210.00 1966 $ 7,565.05 1967 $ 6,965.05 1967 $11,200.55 1968 $13,758.17 1968 $10,869.66 1969 $11,361.51 1969 $10,231.30 1970 $10,231.30 1970 $ 9,346.01 1971 $14,119.92 1971 $ 4,050.18 1972 $ 6,087.00 $57,645.95 $59,349.75 less 8,125.85 less 11,387.82 (see par 3.02.2) (see par 3.02.1 (a) and (b)) $49,520.10 $47,961.93 4.04 This table, which was compiled from the ledgers and vouchers of the appellant company, contains sixty-three items in amounts varying from $65 to $3,960.53, which vary in kind from the keeping of horses to the purchase of an organ and include the purchase of a fur coat, purchase of a tractor and construction of a clubhouse on a farm. ... The appellant shareholder admitted this fact (TS 1 p 51). 4.05.5 The expenses paid by the appellant company for the farm consist of the labour of carpenters, labour of a regular employee, construction wood and the purchase of machinery: Total expenses including purchase of machinery 1966 $ 610.00 1967 $1,783.89 $ 590.00 1968 $2,263.27 “Nil” 1969 $5,518.41 $1,160.00 1970 $3,088.78 $2,804.46 1971 $6,761.80 $1,300.00 1972 $3,927.00 $3,927.00 $9,781.46 4.05.6 The expenses for wood, labour and repairs on the farm may be broken down as follows: 1967 Plumbing $ 124.38 Wood and repairs 355.39 Wood 94.45 Wood 1,177.46 Repairs 176.25 Repairs 443.42 $2,371.35 1968 Labour $ 624.38 Wood 137.67 Labour 467.68 Wood 65.00 Wood 550.89 Labour 1,075.50 $2,921.12 1969 Wood (/ of $907.15) $ 403.58 1970 Labour $ 284.32 1971 Labour $ 640.00 Wood (/ of $829.95) 415.00 Labour 1,078.25 Labour 2,401.47 $ 5,222.62 $10,515,09 4.05.7 The other expenses claimed with respect to the farm are the following: (a) labour of the groom, Mr Ricard, who was paid $3,960.53 in 1968 and $3,334.26 in 1969; (b) medical expenses of the daughter of a farmhand, $117.00 in 1969; (c) repair of electric cables broken by visitors, $624 in 1968 and $969 in 1969; (d) boarding of farm horses (the Legardeur firm), $610 in 1966. 4.06 Expenditure on residence It was also admitted that in 1967 a sum of $1,261.97 was paid by the appellant company for wood used to repair the appellant shareholder’s residence (TS 1 pp 74 and 75). 4.07 Cocktail party and meal expenditures 4.07.1 The appellant explained (TS 1 p 53) that in 1966, following an important political appointment of a friend who had, moreover, introduced him to many customers, he gave a cocktail party (with snacks). ... Year Penalties Tax payable 1966 $ 311.84 $ 1,247.35 1967 516.06 2,064.22 1968 582.19 2,328.77 1969 600.52 2,402.07 1970 546.07 2,184.28 1971 190.56 762.25 1972 412.40 1,649.60 $3,159.64 $12,638.54 B. ...

The appellant was not making investments and except for the two promissory notes (Exhibit A-2), nothing else — notes or preferred shares — had ever been issued by Link. ... The Minister has added the specific amounts noted earlier (1974 — $12,080.04; 1975 — $10,276.49; 1976 — $10,572.74; 1977 — $6,166.60) to the taxable income of the appellant rather than accepting the accounting treatment accorded “X” in the books of the company. ... The payments made as surcharges to purchase invoices were for the purpose of acquiring investments — a capital cost — and investments they remain at this stage of the process. ...