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Exhibit A-4 is a summary of the appellant’s income for the taxation year 1970 and reads as follows: SUMMARY Queensview Apartments Partnership Gross Rentals $734,894 Expenses 637,559 Net Earnings $ 97,335 Arthur Hailey Ltd. share from 1 January 1970- 19 November 1970 @ 17.289% = $14,846 Elphin Apartments Partnership Gross Rentals $298,007 Expenses 299,586 Loss ($1,579) Interest 3,734 Net Earnings $ 2,155 Arthur Hailey Ltd. share from 1 January 1970- 19 November 1970 @ 10.60% =±- 202 English Property Rentals 700 TOTAL: $15,748. Arthur Hailey Ltd Gross Revenue Literary Royalties $214,202.65 Dividends 2,127.82 Interest 9,290.18 Rents: — Queensview Partnership 14,846.43 — Elphin Partnership 202. — English Property 700. ... RENTAL INCOME 734,894 702,015 EXPENSES Advertising 2,994 2,729 Bad debts and collection costs 1,088 926 Bus and car 5,050 4,434 Cablevision 10,689 3,170 Cleaning supplies 2,943 3,759 Elevator maintenance and repairs 5,975 6,770 Employees’ benefits 5,848 5,923 Equipment maintenance and repairs 3,713 2,242 General 3,615 3,077 Hydro, gas and water 73,537 75,746 Insurance 3,896 3,692 Interest and bank charges 13,194 6,988 Maintenance and repairs 21,876 20,216 Management fees 29,396 28,056 Mortgage interest 210,516 216,715 Parking lot — 728 Printing, postage and stationery 1,622 2,391 Professional fees 4,819 4,498 Property taxes 125,285 118,217 Redecorating and painting 4,880 4,451 Refuse disposal 3,313 4,446 Salaries and wages 90,680 79,326 Security 9,003 8,664 Telephone 1,575 1,621 Travel 2,052 1,426 637,559 610,211 NET EARNINGS FOR THE YEAR (note 1) 97,335 91,804 Owners’ Equity, beginning of year 434,429 242,625 531,764 334,429 Capital contribution (withdrawal) (33,333) 100,000 OWNERS’ EQUITY, END OF YEAR $498,431 $434,429 Exhibit A-5 is a partnership agreement dated July 15, 1968 with respect to “Elphin Apartments”. ...

The four directors of the Company were: David Appleby- President — 2 common shares ‘Joe Tanenbaum — Secretary-Treasurer A Freeman- Director Harold Tanenbaum — Director Eight common shares were issued to the directors and the sum of $8 for the shares was deposited in a separate bank account. ... At an average cost of US $342.67 per acre, my share of profit of land sales in 1973 should be calculated as follows: Land sales $188,000 Less — 50% allocated to Pinetree Investments Limited 94,000 $94,000 Less- 6/20th allocated to David Appleby 28,200 65,800 Less — Cost of land (14/20 x 155 acres @ $342.67) 37,180 Gross profit $28,620 Less — Expenses per financial statements 34,316 Less- 50% allocated to Pinetree Investments Limited 17,158 17,158 Less — 6/20th allocated to David Appleby 5,147 12,011 Net profit $16,609 My share of net profit is 1 /14th of $16,609 or $1,186. 5. ... On June 30, 1975, the appellant wrote the following letter to the Director of the District Taxation Office in Toronto: June 30/75 Sidney Zionce 71 Fontainbleau Dr Willowdale Ont Director — Taxation Revenue Canada Taxation 36 Adelaide St E TORONTO Ont Dear Sir: Re 1973 & 1974 income. ...

In 1971, the Appellant reported net income from lot sales as follows: Gross Proceeds $24,700.00 Deduct: Cost $15,345.47 Gross Profit $ 9,354.53 Expenses $ 275.02 Add: Interest Income (6 lots) $ 480.93 Net Income $ 9,560.44 5. ... The Appellant reported a net profit from the sale of the thirteen lots as follows: Gross Proceeds $35,199.50 Cost $28,498.73 $ 6,700.77 Less: Cancellation of 1971 sale 1971 Gross Profit included above 9,354.33 Less: Overclaimed Cost (2,192.21) 7,162.32 Less: Cash collected (1,300.00) $ 5,862.32 Gross Profit $ 838.45 Expenses $ 822.97 Net Profit $ 15,48 7. ...

Despite a counter-offer of $80,000 cash, the price of $100,000 was maintained. 4.04 With the aid of one of their customers, an accountant, the actual appellants fixed the price as follows and the same amounts appear in the agreements (exhibits A-1 and R-1): Business and goodwill $ 59,000 Equipment $ 2,000 Land and building $ 39,000 $100,000 4.05 The vendors accepted to finance the purchasers for $50,000, a mortgage being registered on the sold property. 4.06 Mr Bing Fee Mah, substantially confirmed the testimony of Mr For Yip Chan concerning the price and the conditions of payment and the way the transaction was passed. 4.07 Fifty percent of the payment of the said mortgage would be sent to Mr For Yip Chan’s brother, Mr Bing Chan, who is now living in New York. 4.08 In filing their 1972 income tax return, neither Mr For Yip Chan nor his wife had declared the sold goodwill and paid the involved taxes. 4.09 By reassessment the respondent added, among others, in the actual appellant’s income the following amounts resulting from the sale of goodwill: For Yip Chan $5,900 Carol S Chan $5,900 4.10 The actual appellants are before the Board because of those additions. 4.11 The deemed appellants, in filing their 1972 income tax return, claimed the appropriate deductions concerning the goodwill they had bought in the amount of $59,000. 4.12 The fair market value of the total amount of $100,000 is not in dispute in the present case. 5. ... Canadian Propane Gas & Oil Limited v MNR, [1972] CTC 566; 73 DTC 5019; 3. ...

In his return of income for 1975 the appellant claimed a deduction of $1,926 under paragraph 8(1)(h) of the Income Tax Act, the claim being as follows: Board 27 weeks @ $20 $540 Meal 154 days @ $ 9 $1,386 On assessment the Minister allowed a deduction of $540 only, that is to say, he disallowed the appellant’s claim for meals. ...

This is why a management company named GMBD Ltée (“G” for Mr Gagnon, “M” for Mr Martin, “B” for Mr Bélanger and “D” for Mr Dumoulin — the four key men in MSS Inc) was incorporated to hold a majority of the MSS Inc shares. ... From this date onward, dividends and management fees were paid by the appellant to GMBD Ltée as follows: 1976 1977 Dividends $ 37,014 $ 58,904 Management fees $ 33,600 $ 40,800 The appellant’s turnover was as follows: $4,531,350 in 1976 $3,961,061 In 1977 This reduction of $900,000 in 1977 is explained by an eight-month strike at Alcan: this company represented 50 per cent of the appellant company’s sales. ...

For those years, the Minister regarded the appellant company as having residence in Canada and reassessed the company on the following amounts of income: 1971 — $137,772.47 1972 — $102,430.00 1973 — $ 44,300.00 The decision in this appeal will be determinative of the issues raised in the other appeal of Gini International Inc as to the applicability of withholding tax on dividends paid to Gini International Inc. ... Referring to Sulley v The Attorney General (1860), 5 H and N 711, Lovell & Christmas, Limited v The Commissioner of Taxes, [1908] AC 46 and Grainger & Son v Gough (1896), 3 TC 462, he stated that the function of purchasing goods for export abroad is not the carrying- on of a business in the country of export. ... According to counsel for the respondent, there were two important differences between the case of Firestone Tyre & Rubber Co Ltd (as agents for Firestone Tire & Rubber Co of Akron, Ohio, USA) v Lewellin (H M Inspector of Taxes) 37 TC 111 cited by the appellant and the case at bar. ...

The appellant’s 1975 income tax return contains financial information which is typical of that filed for all the relevant years: AMOEBA REG’D STATEMENT OF INCOME 1975 Per T-1 originally GROSS INCOME filed Innotech Sept/75 $ 75.00 Jan/75 230.00 March/75 275.00 Feb/75 490.00 $ 1,070.00 $ 1,070.00 AMOEBA ENTERPRISES INC Invoices 26,563.61 27,562.31 27,633.61 28,632.31 EXPENSES Outside consulting services 45.00 Automobile expenses 2,244.17 Insurance (50% x $55) 27.50 Interest 149.33 Rent (50% x $1,560) 780.00 Telephone 191.35 Travelling (50% = $1,080.33) 540.00 Materials and supplies 980.19 Promotion, entertaining and parking 972.25 CCA automobile 1,792.32 7,722.11 Less: Personal use of automobile 25% x $4,036.49 1,009.00 6,713.11 7,934.40 $20,920.50 $20,697.91 (The difference between the above income and expense statements is merely that, at the Notice of Objection stage, certain changes were suggested by the appellant, but they are not relevant to the points at issue in this appeal because the expense amounts disallowed by the Minister were the original amounts reported: 1974 — $3,914.56 1975 — 7,933.36 1976 — 5,802.01. ... There was no indication in the evidence that Mr Woolner’s precise or even general design and drafting functions, and the results therefrom, were dictated — or could be dictated — by Petrofina. ... I am not aware that an automobile mechanic, or a plumber for example, performing a task — in his own right and at his own discretion — becomes the employee of the payor merely because the account for the service is rendered based upon an hourly rate charged to complete it. ...

.- $87,468 V-Day Value at December 31st, 1971 $77,000 Taxable Capital Gain (1/2 of $10,468) $ 5,234 and reduced from $12,181.60 assessed by the Minister to $5,234 and setoff against the capital loss claimed by the Appellant. ... —the appellant submits that a disposition within the meaning of the Income Tax Act took place in the year 1972 giving rise to a capital loss of $40,500 in the year 1972; —he is entitled to carry this loss forward into the year 1973; — in the alternative, the appellant submits that a disposition within the meaning of the Income Tax Act took place in the year 1973 giving rise to a capital loss of $40,500 in the year 1973. ... In the appellant’s valuation report the breakdown between land and buildings was not provided, but in that of the respondent’s the following detail was provided: House — $10,000 Out-building — $ 1,000 Land — $53,000 $64,000 Mr Hutchison was of the opinion that while he had made, and provided to the Board, several comparisons dealing with similar buildings in certain cases and certain lands in other cases, the totality of the Subject property must be regarded in: any such evaluation report. ...

In his financial statements for 1979 (Exhibit R-1), the appellant added to the item “Reconciliation of net income” in computing his income for the 1979 taxation vear: Reserve — 1978 $148,617 Reserve — 1979 193,613 X 143,500 111,134 250,000 $ 37,483 For tax purposes, however, the appellant divided the income of $37,483 equally with his former wife Mrs Lucienne Raymond (Lachapelle), and reported his income for 1979 as being $18,742. ...