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In addition, Mr Corbeil submitted Exhibit 1-2, an acknowledgment of indebtedness for the $7,500, which read as follows: (TRANSLATION) St Jude, February 3, 1975 De Smet and Bros acknowledge their debt of $7,500 to Joseph De Smet for money lent in 1971 and 1972: 1971 — $5,000: 1972 — $2,500. ...

The prime object of the company was: to acquire, explore for and produce petroleum, natural gas and all related substances and minerals. 1965 Debits Debits Credits Balance July 28 Deposit $51,000.00 $51,000.00 July 28 Deposit $11,028.00 July 28 Deposit $ 8,272.00 $70,300.00 July 28 Pawnee Petroleums $50,000.00 $20,300.00 July 29 Alexy Spivack $ 1,000.00 $19,300.00 Aug. 3 Maraval Resources $ 8,272.00 $11,028.00 Aug. 3 Nassau Petroleums $11,028.00 — Mr Hilland, who in 1965 was the president of Nassau, said that company had taken a passive interest or put in another way, “had followed along with whatever Pawnee elected to do in the matter of settlement of the litigation with California Standard”. lt is to be remembered that Nassau acquired its 25% interest in the Renke lease from Pawnee on March 31, 1965, that is something more than one year after the litigation had been commenced and some two or three months before the action went to trial. ... It reads: Re: P & N G Lease; Frederick Renke to Pawnee Petroleums Ltd, dated February 19, 1964 This will confirm our agreement with respect to the legal proceedings now being pursued with respect to establishing our title to the above lease. ... Court costs and disbursements arising out of the aforesaid legal proceedings shall be borne as follows: Pawnee 371/2 % Nassau 25% Donaldson 18 /4% Maraval 18 / If the above correctly sets forth our understanding herein would you please execute and return a copy of this letter thereby concluding our agreement in this matter.” ...

Promissory Notes — (84) 4. Illustrations of calculation of interest — working papers 5. ... Eljay Irrigation Ltd — Sale of Shares together with Promissory Notes G. ... The facts of this — if I can just say by way of an aside — the facts of this appeal are, in terms of my research, quite unique. ...

Admissions of the Appellant At the beginning of the hearing, counsel for appellant made admissions concerning different items so that the following amounts be considered as revenue: 1970— income not included $3,649.34 1971— income not included $1,972.97 —unidentified cheques deposited $ 51.25 1972— unidentified cheques deposited $ 74.50 During the evidence, counsel for appellant admitted that penalties were well founded. 4. Admissions of the Respondent After the evidence was given and before the arguments were presented, counsel for respondent made admissions so that the following amounts should not be considered as revenue: 1970— Nil 1971— manure trade $ 500 —unidentified cheques deposited $1,500 1972— sale of one truck $5,999 5. ...

The Facts 3.01 According to the application for extension of time, the taxpayer would have received the notice of reassessment for his 1979 taxation year, “. after the time allowed to properly file a notice of objection”. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are subsections 167(1) and 167(5). ...

Law — Cases at Law — Analysis 4.01 Law The provisions of the Income Tax Act involved in the present case are subsections 10(1), 10(2) and paragraph 20(1)(gg). ... Deductions permitted in computing income from business or property. (1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: 20(1)(gg) Inventory allowance. — An amount in respect of any business carried on by the taxpayer in the year, equal to that portion of 3% of the cost amount to the taxpayer, at the commencement of the year, of the tangible property (other than real property or an interest therein) that was (i) described in the taxpayer’s inventory in respect of the business, and (ii) held by him for sale or for the purposes of being processed, fabricated, manufactured, incorporated into, attached to, or otherwise converted into or used in the packaging of, property for sale in the ordinary course of the business that the number of days in the year is of 365; 4.02 Cases at Law The counsel for the parties referred to the Board the following cases: 1. ...

On the second sale the profit was larger since the appellant retained ownership of the woodlot — a stand of maple (not sugar maple) but a pleasant shady spot, with underbrush where partridge nested and rabbits romped. ... Purchases with little money, entertainment expenses, advertising, social clubs, flowers, gifts and subscriptions — $7,024.52 in 1967 — these are sufficient to conclude that the appellant was in fact in the real estate business. ...

That document was filed to prove the seriousness of that company whose shareholders’ equity was as follows: 1968 1972 1977 $113,258,000 $161,752,000 $263,151,000 A-4 A letter dated March 17, 1976 from the respondent refusing the figures contained in the offer (A-1) made by Walter E Heller & Company. ... The conclusion is that the fair market value of a common share of Cameron Factors Ltd on December 31, 1971, was $80. 3.08 The computation to arrive at that conclusion can be summarized as follows: The annual average income before tax from the years 1970, 1971 and 1972 $ 78,741 Less—tax 26,871 $ 51.870 Capitalized at 121/2% (x 8) 414,960 at 11% (x 9) $466,830 Less Value of priviledge shares 225,000 225,000 Value of 2500 common shares $241,831 $189,960 Value of one common share 97 76 Less or discount of minority shares or 20% 19.40 15.20 Fair market value $78 $61 or 30% 29 22.80 Fair market value $68 $53 The conlusion is that the fair market value of a minority common share of Cameron Factors Ltd on December 31, 1971 was somewhere between $53 and $78. ...

The appellant testified that in 1974 he was required to attend court on 84 different occasions during hours when he was not on duty, and that the travelling expenses incurred in so doing were computed as follows: 4,368 miles @ 18¢ a a mile $786.24 61 half days parking @ $1.50 per half day 91.50 23 full days parking @ $3.00 per day 69.00 The appellant also claimed in his 1974 tax return a a deduction of $46 representing expenses incurred for lunches for 23 days @ $2 per lunch. ...

Three letters, constituting Exhibit A-3, have been filed, and they show that companies by the name of Blyth & Company Incorporated, of Wall Street, New York; Morgan Stanley & Company, of New York City; and Paine, Webber, Jackson & Curtis of New York City, made independent valuations. ... Mr Haythe, of Morgan Stanley & Company, a highly qualified financier who was in charge of the group—or “team”, as he called it—that made the evaluation, gave his credentials, which were quite impressive. ...