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The Minister of National Revenue reassessed the appellant for the 1973 taxation year by Notice of Reassessment No 148487 dated July 27, 1977 on the basis that the appellant was also associated with Wynndel Box & Lumber Co Ltd. ... No appeal came before me with respect to Wynndel Box & Lumber Co Ltd (hereinafter referred to as “Box”). ... Another case which should be considered because of the death of Monrad Wigen is the Federal Court judgment in H A Fawcett & Son, Limited v Her Majesty the Queen, [1979] CTC 303; 79 DTC 5224, (now under appeal to the Federal Court of Appeal). ...

Among the witnesses subpoenaed by the respondent was Mr A Bennett, a partner in: the law firm of Bassel, Sullivan, Lawson & Leake. ... At counsel’s request, Mr Bennett again appeared before the Board on the second day of the hearing, this time represented by his own counsel, Mr M E Sullivan, QC, also a partner in the firm of Bassel, Sullivan, Lawson & Leake. ... The argument for the Minister had been divided into several areas, as Outlined above, and in support of these, the following references were provided to the Board: Confidentiality of income tax returns and non-production of documents (subsection 241(3))—Clemens v Clemens Estate, 52 DTC 1128 (Ont SC); MNR et al v Die-Plast Company Limited et al, [1952] CTC 175; 52 DTC 1082 (Que QB); Weber v Pawlik, [1952] CTC 32; 52 DTC 1059; Miles v Miles, [1960] CTC 37; 60 DTC 1035; Helen Gordon McPherson v Alfred Vang, [1967] CTC 39; 67 DTC 5041; /n re Geldart’s Dairies, [1950] CTC 434; 4 DTC 727; Duncan v Cammell Laird & Co, Ltd, [1942] 1 All ER 587. ...

In this situation we would end up with a Company owned store and parking area and rights in the adjacent shopping centre — eg store No 6080 Kitchener, Ontario. ...

The Minister contended that the “evidence of indebtedness” was that filed as Exhibit A-1, entitled “The Federal Land Bank of St Louis — Deed of Trust”. ...

The appellant assumed an existing mortgage in the amount of $19,000 @ 9% per annum ($188 per month) and $30,000 cash was required on closing (Exhibit A-1). ...

He admits the following allegations of fact contained in the notice of appeal: (a) prior to 1977 the Appellant was an annuitant under a trust governed by a registered retirement savings plan, of which Montreal Trust was trustee; (b) the Appellant was interested in purchasing an interest in the Montclair Apartments, 3375 Oak Street, Vancouver; (c) Peter Ciccone was also interested in purchasing an interest in the Montclair Apartments; (d) a loan of $25,000 at 10 per cent was made from the Appellant’s registered retirement savings plan to Peter Ciccone to enable Peter Ciccone to complete his portion of the purchase of the Montclair Apartments; (e) the loan to Peter Ciccone was secured by a mortgage of Peter Ciccone’s equity in the Montclair Apartments; (f) a loan of $25,000 was made to the Appellant to finance the Appellant’s purchase of an interest in the Montclair Apartments; (g) the loan to the Appellant was secured by a second mortgage of a property owned by the Appellant and located at Delta, BC; (h) in July 1977 conventional mortgage interest rates were 10% — 1072%; (i) the Respondent reassessed the Appellant, adding $25,000 to the Appellant’s 1977 income as the cost of a non-qualified investment (mortgage) acquired in his registered retirement savings plan in 1977. 2. ...

The respondent, on assessment, assumed that the bonuses were paid at the appellant’s direction and “... solely because the appellant desired to benefit himself or his sons and not for any business purpose of the company”. ...

The word “transformer” is defined in Le Petit Robert Dictionnaire Alphatétique & Analogique de la Langue Française, published in 1973, as follows: TRANSFORMER... 1. ...

Issue The issue is whether the work performed by the appellant for R M Louson & Co Limited (hereinafter referred to as “Louson”) was done as an employee of Louson and thereby any remuneration being personal income, or whether it was solely the income of The Omemee Tanning Company Limited (hereinafter referred to as “Omemee”), of which the appellant was the sole shareholder. ...

Without having to negotiate a price, his father sold him the said land for the sum of $44,000 — $2,000 in cash and the balance payable at $2,000 per annum, with interest at 6 per cent. ...