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It is true that in Hansen, supra, Jackett, J allowed the appeal on the ground that “the purpose of the agreement was to make arrangements for the support and maintenance of the wife... ”, and that is the main point. ...

Up to this point in time the appellant had lived 30 years in North Dakota where he worked in Dycks Containers & Forest Products and he was with that business for 20 years. ...

Law — Analysis 4.01 Law The main sections of the Income Tax Act involved in the present case are paragraph 56(1)(h); section 110.1; paragraphs 146(1)(a), (c), (i) and (j); subsection 146(5); paragraph 153(1)(j); and subsection 164(3). ...

When the appellant did move into the building in 1976 he paid rent — but at the same time attempted to deduct capital cost allowance when in fact he played no part in the capital construction of the building. ...

Then paragraph (b) comes into play whereby “... all amounts each of which is an amount equal to the share of the income or loss referred to in this subsection allocated to a taxpayer from a partnership in respect of a particular fiscal period of the partnership shall, notwithstanding any other provision of this Act, be included in computing his income for the taxation year in which that fiscal period of the partnership ends”. ...

Background In April 1971, the appellant purchased the subject property, namely an 105-acre farm being lots 13 and 14, Concession 8, Zone Township, in the Province of Ontario, known municipally as RR # 1, Bothwell, for a consideration of $10,000. ...

The respondent in support of his contentions cited J Clark & Son Limited v MNR, 18 Tax ABC 196; 57 DTC 567; Stanley J Merrett v MNR, 18 Tax ABC 344; 58 DTC 88; Frederick R Phillips v MNR, 28 Tax ABC 81; 61 DIC 677; Ben's Limited v MNR, [1955] CTC 249; 55 DTC 1152; Burrows Motors Limited v MNR, 12 Tax ABC 294; 55 DTC 172. ...

Minister of National Revenue, [1980] CTC 2791, 80 DTC 1689 D E Taylor:—These appeals, heard in the City of Toronto, Ontario, on June 24 & 25, 1980, are against income tax assessments for the years 1970 and 1971 respectively. ...

The letter and document read as follows: Letter TRANTER December 20, 1977 Mr William T Harvey 3400 Rhonda Valley # 50 Mississauge, Ontario, Canada L5A 3L9 Dear Bill: Please take notice, that we hereby accept surrender of all your options to purchase Tranter stock, in accordance with our agreement of December 9, 1977. ...

Contentions According to the appellant, it was contended that: —the farm in question (RR #1, Barrie, Ontario) had been purchased in 1970; —during 1970, 1971 and 1972, he proceeded to build up the farm, fences, fields and buildings; —after a discussion with Revenue Canada in 1974, he commenced to claim the “restricted farm loss” starting with the taxation year 1973 (not disallowed, therefore not appealed); — he anticipated profits before the year 1977. ...