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Antonio Gaspar t ($532.55) Santos \ ($532.54) ($1,065.09) Exhibit A-5 ANTONIO GASPAR OPERATING AS LAKEVIEW FRUIT MARKET BALANCE SHEET AS AT DECEMBER 31, 1972 Assets Current Bank Account—CIBC #69132 426.41 Prepaid Finance—Truck 206.03 Due from SANTOS 532.54 $ 1,164.98 Fixed Accumulated Cost Depreciation Land $19,552.45 — 19,552.45 Building 40,233.75 — 40,233.75 Truck (EE) 1,510.00 — 1,510.00 $61,296.20 $61,296.20 $62,461.18 Liabilities Current Bank Account—B of M—#1017-307 659.91 Note Payable—Truck (EE) 439.60 1,099.51 Long-Term Mortgage payable—Dundas property (DD) 39,452.94 Mortgage payable—Beaconsfield property (DD1) 19,917.45 59,370.39 60,469.90 Proprietor's Equity CAPITAL — Balance—Beginning of period 5,496.35 — Net loss for the period-_ (3,372.07) — Drawings for the period (133.00) 1,991.28 $62,461.18 (#2) ANTONIO GASPAR OPERATING AS LAKEVIEW. ... 800.00 $2,634.57 NET (LOSS) FROM OPERATIONS ($6,012.07) Rental Income 2,640.00 NET (LOSS) FOR THE PERIOD ($3,372.07) Exhibit R-8 Santos Schedule JOSE M SANTOS AND ANTONIO GASPAR Summary of Unreported Income from the SALES PER SALES JOURNAL $84,973.30 — Grape sales per Profit and Loss Statement— September 18 to October 28-72 82,264.10 — Sale of other fruits—Bananas—Unreported 2,709.20 ADD — Grape income for Sept 18 to October 28-72 Statement $ 7,832.68 — Cash sales of grapes and other income not included in sales of $84,973.20 per actual invoices—WP-2 10,056.79 — Sale of wine bottles per Aug 9—Sept 8/72 Statement 1,186.14 — Inventory of wine—Aug 9-Sept 8-72 Statement *$ 2,454.10 Deemed sold (485 bottles or barrels) be tween Sept 9-Sept 17 1972 since no inventory is noted on Sept 18-Oct 28 statement AND NOT INCLUDED IN SALES of $84,973.30 per 100% audit of invoices- entered in Sales Journal—Cost of inventory per WP is 3.50 per case (bottle or barrel). ... UNREPORTED INCOME $25,451.41 LESS Additional Expenses allowed per WP-1 3,278.42 TOTAL UNREPORTED INCOME $22,172.99 GASPAR 50% $11,086.49 SANTOS 50% $11,086.50 SCHEDULE (4) ANTONIO GASPAR INCOME EARNED IN 1972 FROM OCTOBER 29 TO DECEMBER 31, 1972 BANK DEPOSITS—CIBC 836 Dundas St & Euclid acct #69132 October 30 $ 3,758.55) 30 10,860.00) November 3 11,945.93) 6 4,611.83) 10 1,384.75) 15 625.00) T/P stated that money came from 27 615.75) business 3-9-75 conversation December 4 50.00) 4 919.25) 11 339.00) 14 224.20) 27 361.75) TOTAL DEPOSITS $35,696.01 Cost of inventory—Grapes—Oct 29-1972 per statement $ 6,975.20 Purchases — MacKay & Hughes Ltd— Cheques Nov 23 1972 $2,190.00 Nov 30 1972 2,320.00 — Specialty Fruit Co Ltd Cheque Nov 17 1972 90.00 4,600.00 Total available for sale $11,575.20 Less Dec 31, 1972 inventory NIL Cost of goods sold $11,575.20 GROSS PROFIT $24,120.81 DEDUCT—Additional expenses for 2 months WP SCH 6 1,063.18 $23,057.63 SCHEDULE (5) In reviewing this appeal, the Board is conscious of the fact that the fundamental responsibility for filing correct income tax information, and making available appropriate supporting documentation rests with the taxpayer, and many aspects of the evidence brought out put into serious question the extent to which Mr Gaspar fulfilled that role. ...

In fact, the appellant had his office in the same building as A H Roy & Associates. ... The assets of A H Roy & Associates could not be taken into consideration in evaluating the goodwill. ... McNeely, Lecompte & Associates Limited was then incorporated, with the appellants as principal shareholders. ...

This was comprised as follows: Sale Gross Project Closing Date Proceeds Profit E2 June 25, 1976 $ 48,574 $ 10,459 E9 June 30, 1976 75,450 10,743 E15 July 1, 1976 148,931 $ 29,480 $272,955 $ 50,682 House Sales (3) — made Apr. 1/76- July 1/76 $272,955 Lot Sale (1) — with a cost of $27,571 27,000 Renovations and Repairs 106,462 $406,417 (8) In January 1977, a nine month interim financial statement to December 31, 1976 was prepared for management and banking purposes. ... (D) The following inventory was owned by the company: Subdivision Lots — 31 $ 831,298 Unsold Houses — 17 956,319 48 $1,787,617 (12) To finance operations in the March 31, 1977 year the following funds had been utilized: Bank Loan $100,000 Realization of Agreement for Sale 150,000 Loans from Peter Brazolot 47,000 $297,000 (13) A management salary charge of $27,000 was made for the March 31, 1977 year. ... These are — The Queen v V & R Enterprises Limited, [1979] CTC 465; 79 DTC 5399; Toronto Heel Limited v M.N.R., [1980] CTC 2277; 80 DTC 1250. ...

The balance sheets for the years 1977, 1979 and 1981 show the cost of inventory, land, building relating to the farming and laboratory activities as follows: 1977 1979 1981 Farm Lab Lab Farm Lab Lab Farm Lab Lab Inventory $40,435 $ 3,200 $213,039 $ 4,500 $169,634 $ 5,600 Land 54,000 152,000 54,000 152,000 54,000 152,000 Building — — 239,984 429,216 255,287 429,216 Equipment 24,244 143,821 19,393 154,308 23,517 157,965 $118,679 $299,021 $526,416 $740,024 $502,438 $744,781 The laboratory operation of the appellant shows in 1980 and 1981 the following figures (Exhibits A-13 and A-14): 1980 1981 Revenue $913,314 $1,156,955 Net income $190,629 $ 212,488 Moreover, the evidence shows that in the same years the main shareholder of the appellant received bonuses of $150,000 in 1980 and $200,000 in 1981. ... A Well, I’ll just have to try and — you see I’ve been with him for three years and the first year l came up he had like kind of a Mickey Mouse operation. ... Pursuant to the financial statements the land on Charlotte Street is worth $122,000 ($122,000 + 7 $17,428 + $30,000 $47,428). ...

The taxpayer reported, on his return of income for the 1975 taxation year, a capital gain on the disposition of the following property (all in the Province of Manitoba (“the property”)): S / 18-35-25W S / 28-35-25W S / 20-35-25W S / 17-35-25W SE /4 7-35-25W NE /4 8-35-25W The reported proceeds of disposition on the property were $170,000. ... A real estate listing agreement dated February 12, 1975 between the appellant and C & L Realty Limited was also introduced into evidence as Exhibit A-20. ... Write stating full particulars to: C & L Realty, 2727 Portage Avenue, Winnipeg, Man. ...

We therefore propose to adjust 1973 as follows: Gas, Insurance, Repairs Claimed $ 675.32 Rentals Claimed 520.00 $1,195.32 Allow one-half Business use 597.66 Adjustment 1973 $ 597.66 Reassessment will be deferred for fifteen (15) days to allow you an opportunity to make any representations you feel necessary. ... Proposed settlement Office Advertising Gas, Oil (Sup- Breakdown of Taxable & Promotion Rentals & Repairs plies) Benefit 21.00 11.90 20.00 8.70 3.20 Health Care 30.00 59.95 28.30 20.00 6.60 4.25 Prizes 50.00 11.45? ... 16000 “Pers 22.10 160.00 7.30 14.90 34 12 Rentals 160.00 34.12 12.75 16.65 Standby charges 360.00 8.30 12.80 520.00 502.60 Schedule of Expenses Claimed Proven Non-allowable Advertising & promotion 520.30 502.60 17.70 Rentals 520.00 — 520.00 Office 34.12 34.12 — Travel 10.00 10.00 — Accounting 20.00 20.00 — Car expenses 696.32 679.72 16.60 Personal use 10% nil (67.97) 67.97 1800.74 1178.47 622.27 Expenses disallowed previously 597.66 Additional non-allowable expenses 24.61 Solution Based on above, the taxpayer should be disallowed some additional expenses. ...

The data given in his report was as follows: (3) Lot 149 —4.5 acres — No buildings — Unserviced — Located in the South East portion, or Lakeview subdivision —Sold in 1971 for $26,000 —Sale price per acre—$5,777.87 (4) Lots 29 & 30, Plan Lethbridge 4368K — 10.0 acres — No building — Unserviced — Located in Lakeview subdivision, this parcel was subdivided and developed in 1972 —Sold in 1972 for $65,000 —Sale price per acre—$46,500 (sic) (5) Lots 1 to 20, Block 7, Plan 6799 JK —4.60 acres (net) — No buildings — Unserviced — Located in Lakeview subdivision, this property was surveyed for development prior to sale and was developed into twenty (20) residential building lots —Sold in 1972 for $40,000 —Sale price per acre—$8,675.65 No “3” was sold pursuant to an agreement of sale, the terms of which were not disclosed. ...

Medical practitioner’s automobile and telephone expenses — Farming losses. ... Dr Todd, having left British Columbia to take up residence in California, did not appear in person before the Board at the hearing of his appeal, but one Peaker, administrative officer of The R B White Clinic — and himself an orchardist — testified that he had been requested by Dr Todd to review and assess the prospects of the farm before the appellant acquired it in 1964. ... A statement filed as Exhibit R-2 discloses the treatment accorded the loss claimed as a deduction by Dr Todd to have been as follows: Claimed Allowed Disallowed Taxes and Water $ 394.06 Irrigation Water — Allow 100% of $50.00 $ 50.00 Taxes —Allow 25% of $344.06 $ 86.01 $ 258.05 Insurance (not crop insurance) 4.14 Disallow 100% Nil 4.14 Electricity 164.89 Disallow 100% Nil 164.89 Interest (on purchase of property) 1,473.31 Allow 25% 368.32 1,104.99 Simca Car Expenses and Capital Cost Allowance (Wife’s car) 341.02 Disallow 100% Nil 341.02 Dwelling Repairs & Depreciation 543.31 Disallow 100% Nil 543.31 Total Disallowance $2,416.40 Thus the total of $504.33 allowed was said to relate to wages and tree-removal costs and other matters directly related to the orchard, and bore a definite relation to the earning of such income as the orchard had been able to produce. ...

Minister of National Revenue, [1982] CTC 2302, 82 DTC 1332 D E Taylor:—These appeals, heard on common evidence in Edmonton, Alberta, on February 10, 1982, were lodged against income tax assessments for the following years: Dr Lloyd G Powell (“Powell”) — 1975 & 1976 Polaris Holdings Ltd (“Polaris”)— 1975 & 1976 Mr Neil G Orser (“Orser”) — 1975 Mr Michael Piro (“Piro”) — 1975 There were four matters at issue in these appeals, all gains on sales or property — the total appeal therefore in all aspects reflects a “trading case” dispute. ... Triple Crown — Powell had lived on an “acreage” lot in the country ever since moving to Edmonton; — He liked horses; — He considered the prospect of raising horses in his retirement years would be a good objective; — Triple Crown would have been suitable, as a matter of fact, because it had 160 acres as opposed to 40 at the present farm site which, for location reasons only, was more suitable; — On the sale of Triple Crown, he immediately purchased a new “horse” farm — the current 40 acres, and has invested some $250,000 therein. Apartment — This purchase was in the same manner as the other rental holdings in Yellowknife. — The decision to sell had been that of Ibrahim, not Powell. ...

In his returns for the said years, he stated as present employer — “Pioneer Life”. ... In filing his 1975 T-1 tax return, the appellant claimed and the respondent subsequently allowed the following expenses: 1975 Expense claimed (as filed Item per return) Allowed Disallowed Car Expenses: Interest $ Nil $ 417.48 Insurance Nil 137.67 Gasoline 1,109.33 367.87 Maintenance & repairs 999.92 770.35 CCA 1,590.00 1,184.02 $3,699.25 $2,877.39 Less 35% personal use Nil 1,007.09 $3,699.25 $1,870.30 $1,828.95 Licence 133.00 133.00 Nil Parking 45.00 45.00 Nil Car Washes 33.50 33.50 Nil Advertising & Promotion 82.00 90.25- 8.25 Travel & Accommodation 208.78 Nil 208.78 Entertainment 506.19 269.32 236.87 Training allowance 190.00 190.00 Nil Telephone 75.35 29.55 45.80 Office Equipment & Supplies 854.50 10.37 844.13 Winnipeg Flying Club 646.58 318.01 328.57 $6,474.15 $2,989.30 $3,484.85 5. ... With respect to “Fire & Liability Insurance”, I find that this is not a legitimate expense under the circumstances. ...