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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. ...

L’appelante en effet a acquis de nouveaux clients importants dont la nature et le montant des primes sont tels que ci-après décrits: Noms de nouveaux clients Primes Une compagnie de construction $ 52,000 Une compagnie de matériaux de construction $ 35,000 Une compagnie de bois $ 88,000 Une compagnie d’acier $ 70,000 Un commerce de moulin à scie $ 14,000 $259,000 Le revenu additionnel qui en est découlé constitue environ $40,000 à $45,000 de commissions. 3.13 Un autre élément d’augmentation de revenus, selon M Castelli, fut l’augmentation des primes d’assurance-automobile. ... Sa Majesté la Reine c Baine, Johnston & Co Ltd, [1977] CTC 556; 77 DTC 5394; 8. Crosbie & Co Ltd c MNR, [1978] CTC 2091; 78 DTC 1083; 9. Walter J Burian c Sa Majesté la Reine, [1976] CTC 725; 76 DTC 6444; 10. ...

Rosenhek & Machlovitch, Suite 1700 — One Westmount Square, in the City of Westmount, Province of Quebec, on March 17th, 1977, or on such earlier or later date as may be agreed upon by the Purchaser and the Vendor. ... Findings The position of counsel for Mr Senecal is a rational one — that Senecal simply would not have accepted $50 for stock worth some $28,850 — and counsel made a convincing case for the acceptance of his position. ... Whatever else may arise from an examination of this matter, his claim to a capital gain is unfounded — the $26,450 at issue was not for the sale of his stock — it is salary income to Senecal in the year 1977. ...

Veuve Clément Bouchard & Euclide Bouchard es qualité v Diane Lepire, [1974] CA 616; 17. ... Union Insurance Society of Canton Limited & André Arsenault, [1961] S.C.R. 766; 22. ... Eugène Lagacé <& George Lagacé v MNR, [1968] CTC 98; 68 DIC 5143; 41. ...

A I don’t know whether I can answer you that directly — you know — everything that one does in business today — you have the two (2) facets: one is the operations, and the other is the financial, if you want, and it is very complex, especially to a person such as myself, and I do depend upon professional counsel. ... Q A fair assumption — there would be no problem with these preferred shares?... ... Alpine Drywall & Decorating Ltd v MNR, [1966] CTC 359; 66 DTC 5263; 6. ...

Of this amount the payments made to Lamontagne & Lamontagne were again dropped by the appellant as were amounts totalling $950 paid to Eric M Lack, Notary, and to the firm of O'Brien, Hall & Nolan. In issue was an amount of $1,964.23 in Canadian currency paid to Hamburger & Green, Counsel lors at Law. ... Exhibit A- 7 is a bill for $600 from O'Brien, Home, Hall, Nolan, Saunders, O'Brien & Smyth, Barristers & Solicitors, and deducted by the appellant, $200 of which was disallowed because it dealt with the St Felicien project. ...

A large insurance broker, Thomason & Saunders, approached Clarkson, Gordon & Co, Trustees in Bankruptcy, with respect to the purchase of the list of customers and negotiated with one Donald Gardner, CA, of the bankruptcy division of Clarkson & Gordon, who was appointed official Trustee in Bankruptcy as a result of a Proposal filed on February 4, 1975. ... There was a subsequent letter, however, written on April 22, 1975, on Hugh & McKinnon Ltd letterhead, with the knowledge and approval of Mr Davidson, whereby the people on the customer list were again contacted and requested to direct their inquiries to Mike and Brian “now located at Hugh & McKinnon Ltd, 5678 — 176th Street, Surrey, BC”. ... At 730 and 6447 respectively, Collier, J states: In my opinion, when one views the “practical and commercial aspects”* [1] of this purchase, the plaintiffs were in reality acquiring, or endeavouring to acquire, an opportunity for potential future customers or business — the trade of the clients of C F Graves & Co. ...

Station Canada & Gulf Terminal Inc v. Minister of National Revenue, [1981] CTC 2044 Roland St-Onge [TRANSLATION]:—The appeal of Station Canada & Gulf Terminal Inc came before me on May 22, 1980 in Quebec City, Quebec. ... Representing the firm of Ménard, Marsan & Associés of Rimouski, Mr Ménard determined a valuation day or “V-Day” value of $0.32 per square foot. The witness Jacques Sauriol, of the firm of Leroux, Beaudry, Picard & Associés Inc, set the value at $0.265 per square foot, without taking improvements into account. ...

Station Canada & Gulf Terminal Inc v. Minister of National Revenue, [1980] CTC 2805 Roland St-Onge:—L’appel de la compagnie Station Canada & Gulf Terminal Inc est venu devant moi le 22 mai 1980 dans la ville de Quebec (Quebec). ll s’agit de déterminer la valeur d’un terrain au 31 décembre 1971 afin de connaître le montant du gain en capital pour l’année d’imposition 1975. ... Représentant la firme Ménard, Marsan & Associés de Rimouski, monsieur Ménard a déterminé une valeur au jour d’évaluation, ou “V-Day” de $0.32 le pied carré. Le témoin Jacques Sauriol de la firme Leroux, Beaudry, Picard & Associés Inc, sans tenir compte des améliorations, a fixé une valeur de $0.265 le pied carré. ...

Shultup Management & Investments LTD v. Minister of National Revenue, [1972] CTC 2655 The Chairman (orally):—This is an appeal by Shultup Management & Investments Ltd, a company incorporated under the laws of the Province of British Columbia, against a Notice of Reassessment by the Minister for the taxation year 1962. ... Zielinski went to the specified location and staked the area of the old workings, and continued on to stake a total of 14 claims, during the course of which assignment he managed to personify the classical mind’s-eye picture of a prospector chipping away at outcroppings and deciding by “an eyeball assessment” — a talent gained through years of experience — whether or not a particular area was worthy of staking and recording or not. ... I have read the evidence in great detail, and I find nothing in the line of fact that would allow me to infer that the appellant company was the person who made the arrangement — or the corporation that made the arrangement — with Cohen as contemplated by subsection 83(3). ...