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Obviously, a taxpayer is entitled to arrange his affairs so that he will pay the least amount of tax but he is not entitled to disturb his own affairs to arrange those of another taxpayer — in the present circumstances, Rideau Terrace Apartment Limited. ...

From the year 1953 until about December of 1963, the appellant was employed by Leslie Bongard & Co Ltd, a stock brokerage firm with offices in the City of Windsor, in the County of Essex, and elsewhere. ...

The amounts added back to his income for the respective years were as follows: (a) Architectural and engineering costs not laid out to earn income in 1962 Britannia “800” /2 of 5,285.97 $ 2,642.99 (b) Architectural and engineering costs not laid out to earn income in 1963 Britannia “800” /2 of 1,545.28 772.64 (c) Architectural and engineering costs not laid out to earn income in 1964 Personal residence J Abugov— /2 of 1,134.02 567.01 12th Ave. ...

The Board also notes that the financial statements of the appellant, prepared by Thorne Gunn & Co, Chartered Accountants, attached to the income tax returns for the years in question show as gross income from his veterinary practice the amounts of $89,167, $106,001, $122,119 and $122,287 respectively described in each year as “Income from professional fees, farm, clinic and government retainer fees”. ...

In 1972 Johnston found itself in financial. difficulties and Johnston Holdings agreed to sell all of the issued and outstanding shares of Johnston to C J Hodgson & Co Inc, another brokerage firm. ...

It is located in the general office premises of Rosenberg, Smith, Paton, Hyman & Matlow, a Toronto law firm. ...

A premium is deductible under a registered retirement savings plan (if the taxpayer already contributes, as in the present case, to a registered pension plan) only if the contribution to the said registered plan for the’ year (8(1)(m)(i)(ii)) (amount of $1,593.40 + 2,059.72 $3,653.12) plus, the contributions of $1,000 to the registered retirement savings plan do not exceed $3,500 12+ $1,000 $4,653.12). ...

One thing that has happened though — the market is Still fairly conservative, in that the photography that is most often bought is that which is most established, so the older the photographer is and the longer the photographer has been exhibiting and the more reviews and publicity the photographer has, the more that work is being purchased, because it is bought often by corporate collectors and individual collectors as an investment.” ... (SN p 83) (c) “... It takes a great deal of exposure and education for people to become accustomed to unknown artist’s work to start with... they need the support of continuing exhibitions and continuing visual exposure to accept work, and that is the reason for the lack of sales. ...

The Facts 3.01 The only witness for the appellant was Mr Raymond J Connors, CA, a member of the firm Touche Ross & Co and co-executor and trustee of the last will of Mrs Viola Louise Campbell. ... If it is required, those provisions shall be quoted in the analysis. 4.01.2 Counsel for both parties also referred to: (a) The City of St John’s Act (consolidation 1952) Section 2 — definition of “Building Lease” “Building Lease” shall mean, with reference to leases made after August 2nd, 1921, a lease of a vacant piece of land on which the lessee covenants to erect a building or to pull down an old building and erect a new one on the site; and, with reference to leases made before August 2nd, 1921, shall mean a lease of a vacant piece of land on which the lessee or his assigns has erected a building or has pulled down an old building and erected a new one, and shall include any extension of an original lease whether the extension is expressed to be an extension or not of the said original lease. ...

Mr Horta, who was the field supervisor of Sargent while he was in its employ (and there was some confusion here), suggested that he completed his work through a limited company which he had incorporated, namely, Development Control & Planning Ltd (hereinafter referred to as “Development”). ... Two other cases, both in the Federal Court — Trial Division, were referred to: The Queen v Robert B Atkins, [1975] CTC 377; 75 DTC 5263, a decision of Collier, J; and, Francis Lorenzen v The Queen, [1981] CTC 377; 81 DTC 5251, a decision of Mr Justice Grant. ...