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At 567 & 6376 respectively, Mr Justice Jackett then President of the Exchequer Court of Canada stated: With great doubt as to the correctness of my conclusion, I am of opinion that section 139(1)(e) does not operate to make a non-resident person subject to Canadian income tax in respect of a profit from an adventure that otherwise does not amount to, and is not part of, a “business”. ...

On September 28, 1973, Underwood McLellan & Associates Ltd wrote Carburn Aggregates, giving their engineering report on existing proposed developments of the Carburn Angus Pit which included the Ogden pit. ...

On April 5, 1960 these two men entered into what is commonly known in the legal profession as “a buy-sell agreement”, whereby the survivor had the right but not the obligation to purchase the shares of the deceased. (! ...

I quote here certain statements made by Thomas J Collins for the year ending May 31, 1972, on the Bob-O-Link Farms report: Following the purchase of the “Silver Hills Ranch’’ in June, 1971, from M & A Davis, careful consideration has been given to the various alternatives open to us that would insure a successful farm operation.... ...

. /. The assessment appears to obliterate the distinction between active and passive business which is prescribed in the Income Tax Act. 8. ...

”’... Here is a full-time professor at Ottawa University, he spends 30 or 40 hours a week in the building, he has an office, he has a secretary, if you look him up in the Ottawa University phone book, his phone number is in there, he’s a member of the pension plan, a member of the faculty union. ...

He said: “! considered it a 15- to 20-year proposition before it would be good.” ...