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Contentions For the appellant: — The taxpayer, at the inception of and prior to acquisition, took the initi- ative and procured an agreement between the co-owners, in writing, maifestly designed to preclude sale. — The taxpayer has a demonstrable history of procuring real estate, with partners, and eventually acquiring the total interest, and never with the intention of resale. — The taxpayer had a consistent portfolio of investments in realty since 1956 (which continues to now) obviously not intended for resale, and has never engaged in speculation in retail, even up to the present time. — No effort had ever been made to sell the property notwithstanding inordinately attractive circumstances for sale (if acquisition and sale for profit was intended) by reason of development relating to proposed Highway 401, widely publicized in or about April, 1971. — The property was only sold once expropriation become imminent. — Investment in realty as a hedge against inflation is the antithesis of an adventure in the nature of trade. ... For the respondent: — The appellant at all material times was a lawyer practising in the City of London, whose practice included real estate transactions, and as a result thereof the appellant was very knowledgeable with respect to land values and speculation in land in and about the City of London; — in purchasing the property in 1969, the appellant had three partners, one of whom being a real estate agent, and another being a trader in real estate; — the appellant and his partners did nothing to improve the property or to convert it into an income-producing asset. ...

It was also admitted that at all material time R & M Heating Ltd had only one employee, the appellant. ... It named the trustees for the plan and provided for the coverage of additional employees of R & M Heating Ltd. ... R & M Heating Ltd had and still has only one employee, the appellant. 3. ...

Payment of purchase price to be carried over 1 year as follows: 1 / Down 1/3 6th Month 1 / 12 Month (6,324.59) (6,324.59) (6,324.59) 3. Use of Agency name (BROWN) for 3 years if required (ie Lester & Brown). 4. ... LESTER & SON, and W. A. LESTER & SON has agreed to purchase the attached list of customers with related information for the price hereinafter set forth. ...

Mr Koch proceeded to obtain a rental property available through the British Government in Slough in England and formed an English company in which he held 50% of the stock and his English representative — I believe his name was Wiseman — held the other 50%. ... These, briefly — or perhaps not too briefly — are the facts as they have unfolded during the course of the hearing. ... What then did he do — what was there in his actions — to convince me that this was really his intention? ...

Calculation of 146(5) via 146(1)(c) Employment Income $ 9,142.79 Pension Income 2,758.05 RRSP Income 2,042.47 13,943.31 UIC Premiums (110.83) Union Dues (64.20) Earned Income—146(1)(c) 13,768.28 20%.20 2,753.66 Less RPP 545.54 146(5) Deduction $ 2,208.12 2. ... Calculation of 60(j) Actual Contributions 3,892.00 Deduction per 146(5) 1,871.34 Revised Total per 60(j) $ 2,020.66 C. ... Correct 60(j) amount $ 2,104.85 Correct 146(5) amount 1,787.15 Pension Income Deduction per 110.2(4) Pension Income $ 2,758.05 60(j) Deduction 2,104.85 Pension Income Deduction $ 653.20 ...

A certificate for 47 shares of Léandre Lachance & Associés Inc was issued in the appellant’s name (Exhibit A-6). ... This document is entitled “Statement of Monies owed to L Lachance & Ass by Bruno Michel”. ... Act — Case law — Analysis 4.01 Act The principal sections of the Income Tax Act relating to this case are sections 3, 9, 12, paragraph 12(1)(g), sections 96 and 248. ...

Act — case law — analysis 4.01 Act The provisions of the Income Tax Act involved in the case at bar are paragraph 8(1)(b) and subsections 62(1) and (3). 4.02 Case law and legal theory 1. ... The Board is therefore obliged also to dimiss the appeal of the appellant regarding the costs of cancelling her lease. 4.03.4 Moving costs — $169.75 This item concerns $69.75 of meal expenses and $100 for rental of the truck (see paragraph 3.01.4). ...

Law — Cases at Law — Analysis 4.01 Law Section 62 of the Income Tax Act is the provision involved in this case. ... Mr Justice Collier of the Federal Court — Trial Division said concerning these expenses: The disputed outlays were not, to my mind, moving expenses in the natural and ordinary meaning of that expression. ... I shall quote it again: “travelling costs... in the course of moving the taxpayer and members of his household from his old residence to his new residence”; the words “... in the course of moving...” are large enough to include the said expense. ...

He told Mr Rafaat Mahadeen: “... if (you) can get rid of those units (you) would be further ahead to sell them, because in the future it will cost (you) too much money to put a new roof on.” ... (f) They saw the buildings from the outside and they bought the properties without seeing the interior —“... that was the biggest mistake we made.” ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act, SC 1970-71-72, c 63, as amended, involved in the present case are section 3 and subsections 9(1) and 248(1) (definition of “business”). ...

While Mrs Shirley was peacefully sitting holding her 20-acre parcel of land located immediately to the south of the City of London, the St Lawrence Cement Co — acting completely on its own initiative — made application to her early in 1967 for a right-of-way across her said property for the purpose of connecting its property (which lies to the south and west of Mrs Shirley’s property) with the CNR line running from London to Port Stanley by constructing therefrom a spur line on the proposed right-of-way. ... The company’s liabilities, endorsed by the father, were as follows: $1,580.21 — overdraft for NSF cheques 40,000.00 — bank loan 36,972.63 — mortgage on the new building 20,990.83 — trading account According to a 1965 record, $88,370.59 represented the amount that the company owed the father as at the end of 1965. ... Counsel for the appellant argued that Mr Atkinson, Sr’s business was a three-pronged affair — law, lending money and dealing with Risteen and other companies; that he used them indiscriminately, and that it would be unfair to segregate one from the other because it was a one-man affair. ...