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The notice of appeal reads in part as follows: — On December 31, 1971, during the years on appeal and even today, the appellant was and still is a farmer. — On December 31, 1971, during the years on appeal and even today, the appellant was and still is the owner of a property located in the town of Mascouche, which he had acquired from his father on June 11, 1963. — Long before December 31, 1971, the town of Mascouche had experienced, and was still experiencing during the years on appeal, a substantial amount of property development. — On December 31, 1971, such development was occurring on land adjacent to the appellant’s land. — During the years on appeal, various sales of parcels of land were made by the appellant. — By notices of assessment issued on January 20, 1977, the respondent assessed a capital gain for the years on appeal, relying on the fact that the fair market value of the appellant’s land on December 31, 1971 was three cents ($0.03) per square foot. — On June 23, 1977, the appellant filed notices of objection to the said assessments. — To lend support to his notices of objection, the appellant asked Les Estimateurs Professionnels Leroux, Beaudry, Picard et Associés Inc to prepare an appraisal of his land, dated December 31, 1971. — The said report established that the value of the said land was nine cents ($0.09) per square foot. In his reply to the notice of appeal, the respondent states: — Pursuant to agreements of sale between the purchaser and the appellant in 1973, the latter sold various parcels of land in 1973, 1974 and 1975; — the sale price for the various properties had been agreed to between the parties in 1973 when the agreements of sale were signed; — as a result of the sales of these properties, the appellant reported the following amounts as Capital gains: Statement of sale of capital property 1973 Sale of 70,872 sq ft at 8¢ per sq ft $ 5,669.76 Value on 31/12/71:.0772 per sq ft 5,315.40 Capital gain $ 354.36 Statement of sale of capital property 1974 Sale of 55,449 sq ft at 8¢ per sq ft $44,279.92 Value on 31/12/71:.0772 per sq ft 41,512.42 Capital gain $ 2,767.50 Statement of sale of capital property 1975 First sale Sale of 321,685 sq ft at 80 per sq ft $25,734.80 Value on 31/12/71:.0772 per sq ft 24,126.37 Capital gain $ 1,608.43 Second sale Sale of 30,165 sq ft $ 3,000.00 Value on 31/12/71:.0772 per sq ft 2,262.00 Capital gain $ 738.00 Total Capital Gain $ 2,346.43 — the respondent appraised the said properties in order to determine their value on December 31, 1971 and valued them at.02770 per sq ft; — accordingly, by assessments dated July 7, 1978, the respondent established the following amounts as capital gains: 1973 Proceeds of disposition $ 5,669.76 Adjusted cost basis (.02770 per sq ft) 1,963.15 Revised capital gain $ 3,706.61 1974 Proceeds of disposition $44,279.92 Adjusted cost basis (.02770 per sq ft) 15,330.54 Revised capital gain $28,949.38 1975 Proceeds of disposition $28,734.80 Adjusted cost basis (.02770 per sq ft) 9,746.24 Revised capital gain $18,988.56 Contentions For the appellant: — The respondent’s appraisal is unacceptable, because it does not take into account the special location of the appellant’s property. — The appraisal by Les Estimateurs Professionnels Leroux, Beaudry, Picard & Associés Inc, a copy of which is attached as an integral part hereof, is the only fair appraisal in the circumstances. For the respondent: — The burden of showing that the respondent’s appraisal is incorrect rests on the appellant. ...

The appellant sold no horses since 1974 and the following is a picture of his profit and loss for the years 1974, 1976, 1977 and 1978: 1974—$11,181.20 (loss) 1976— $ 5,514.00 (loss) 1977— $ 5,019.37 (loss) 1978— $ 1,135.00 (profit) I refer specifically to the case of William Moldowan v Her Majesty The Queen, [1977] CTC 310; 77 DTC 5213. ...

The proceeds thus received by appellant from the sale of the said shares in the capital stock of Fibracan were reinvested, for example, in shares quoted on the Stock Exchange — to cite only a few, Industrial Acceptance Corporation, Dupont of Canada, Great Lakes Paper Ltd., Price Co., Abitibi, Alcan, Chemcell, Traders, Westcoast, Bell Canada, American Growth Special, Acklands Ltd., etc. in the same way as an individual makes investments. 22. ... This report, which considered inter alia the situation of the Canadian market, anticipated production costs and the planned financial structure of the business, forecast the following profits: Net Profit Net Profit before after after Available for Year Sales Sales Tax Tax Tax Tax Reinvestment^ 1 $ 549,600 $ 67,250 $ 43,900 $ 89,900 2 870,200 181,600 98,610 133,410 3 1,059,600 254,660 135,250 165,490 The factory called for an initial investment of $220,000. ...

Minister of National Revenue, [1972] CTC 2257, 72 DTC 1225 J O Weldon:—This appeal of the appellant Griffin Head Farms Limited (“Griffin”) initiated by Notice of Appeal dated April 2, 1971 with respect to its 1966 and 1968 taxation years, and those of Allied Vegetable Farms (Kingsville) Limited 71-238 (“Allied”), Edward Remark & Sons Limited 71-239 (“Edward Remark & Sons”) and Frank Remark & Son Limited 71-247 (“Frank Remark & Son”) initiated by Notices of Appeal all dated April 2, 1971 with respect to their 1966, 1967 and 1968 taxation years were heard together at Windsor, Ontario on September 22, 1971 under the Tax Appeal Board as it was then constituted. ... In the fall of 1964, Frank Remark and Edward Remark incorporated three more corporations: (a) Frank Remark and Son — to which corporation Griffin sold the Jasperson Farm accepting a promissory note as consideration; (b) Edward Remark & Sons — to which corporation Edward Remark and Frank Remark sold the farm property which they had Originally used in their partnership business Remark Orchards taking a promissory note as consideration therefor; (c) Allied — to which corporation Frank Remark and Edward Remark sold a number of greenhouses which they had originally used in their partnership business Remark Orchards accepting as consideration therefor a promissory note and the issued shares of Allied. 7. ... In that regard, Edward Remark testified as follows: Sometime before 1963 — I can’t recall exactly when, but my brother and I both agreed and approached Mr Riddell in Windsor. ...

(Sgd) A F Rodger Cancelled cheques were identified also and filed with the Board by the appellant as follows: Date Payee Purpose (According to Appellant) Interim Home 1973 Alimony Mortgage Error July 20 Barbara A Brooks $ 500.00(xx) $ 500.00 July 20 Crown Life Insurance $ 223.00 $ 223.00 August 24 Barbara A Brooks 1,000.00 446.00 $1,446.00 September 25 500.00 223.00 $ 50.00 $ 773.00 October 23 500.00 223.00 50.00 $ 773.00 November 23 500.00 223.00 $ 723.00 December 18 500.00 223.00 $ 723.00 $5,161.00 $3,500.00 $1,561.00 $100.00 (xxx) (x) The appellant explained that the excess amount of $100 (marked x) had been adjusted in later payments and therefore the total amount involved ($5,061) did not include this $100. ...

Lock wood 267.41 August 1-December 31, 1977 Rental Income $ 800.00 Expenses $2,130.70 Less: % Personal 1,065.35 1,065.35 (265.35) Capital Cost Allowance $(1,523.00) Net Loss 1,788.35 Total Net Loss $ 2,055.76 3.02 The respondent did not permit the appellant to deduct the amount of $2,055.76 as a rental loss in his 1977 taxation year and recomputed the appellant’s income as follows: January 1-July 31, 1977 Rental Income $1,120.00 Less: Expenses $2,482.23 Less: Personal Portion 2,234.00 248.23 Rental Profit 871.77 A. Appellant’s Share (1 Z>) $ 435.88 August 1-December 31, 1977 Rental Income $ 800.000 Expenses $2,130.70 Personal Portion 1,917.63 213.07 Rental Profit 586.93 Less: Capital Cost Allowance 190.10 396.83 Less: Interest Expense 63.99 Net Rental Profit $ 322.84 B. Appellant’s Share (100%) $322.84 Total Net Rental Profit: (A & B) $ 758.72 3.03 Concerning the period from January 1 to July 31, 1977, the expenses of $2,482.23 claimed by the appellant are detailed as follows. ...

The appellant is a professional engineer, practising as Gerald J Foley & Associates, Engineering and Management Consultants, c/o Gerald J Foley, 201-2727 Portage Avenue, Winnipeg, Manitoba. ... Location & Survey by: Mid-Canada Consultants Limited; Exhibit A-7—Plan—Dwg No 202—Proposed Mobile Home Park, City of St Vital (Prepared by Gerald J Foley & Assoc); Exhibit A-8—Plan—Proposed site for Mobile Home Sub-Division (Prepared by B J Fleishman April 6/70); Exhibit A-9—Sketch Plan—Detached Housing Complex (Prepared by Mid-Canada Consultants Ltd April 17, 1970); Exhibit A-10—Inter-departmental Memorandum dated March 5, 1970 to the Honourable Leonard S Evans, Minister of Industry & Com- merce, Manitoba, from Lome D R Dyke, Deputy Minister, Industry & Commerce, Manitoba; Exhibit A-11—Letter dated June 1, 1970 to Mr E A Levin from Northwest Design & Fabrication Limited, Winnipeg, Manitoba. ... Description Page 1 Surveyor’s sketch of land 1 2 September 23, 1969—letter from G J Foley to The Comax Corporation of Canada Ltd 1A 3 Option to Purchase dated November 12, 1969 between Victor John Mager and Gerald J Foley and Associates 2 4 Option to Purchase dated November 31, 1969 between Louis Jules Mager and Etiennette Mager, and Gerald J Foley and Associates 7 5 Prospectus proposal—Six Wheels Limited, dated December 6, 1969 14 6 November 4, 1969—letter from Neonex International Ltd to Gerald J Foley 20 7 November 10, 1969—letter from Neonex International Ltd to Gerald J Foley 21 8 June 23, 1971—memo from Gerald J Foley to Neonex International Ltd 22 9 November 25, 1969—memo from Gerald J Foley to Prospective Partners 23 10 January 21, 1970—letter from Mid-Canada Consultants Limited to Commodore Properties 26 11 February 17, 1970—letter from Brock & Brock to Gerald J Foley 27 12 June 17, 1970—letter from Rohne-Trumpour Realty Services Ltd to Gerald J Foley 28 13 Invoice dated June 26, 1970 from E Karl Farstad & Associates Ltd to Gerald J Foley 30 14 June 26, 1970—Letter from E Karl Farstad & Associates Ltd to Gerald J Foley 31 15 July 17, 1970—letter from Gerald J Foley to Comax Corporation of Canada Ltd 40 16 July 20, 1970—letter from Comax Corporation of Canada Ltd to Gerald J Foley 43 17 Offer and Acceptance dated August 1, 1970 45 18 Option to Purchase dated September 1, 1970 between Gerald John Foley and Compark Developments Ltd and Six Wheels Limited 46 19 June 19, 1970—letter from Gerald J Foley to Robbins Equipment Corp 69 20 July 2, 1970—letter from Detroiter Mobile Homes to Gerald J Foley 70 21 July 10, 1970—letter from Detroiter Mobile Homes to Gerald J Foley 71 22 July 20, 1970—letter from Detroiter Mobile Homes to Gerald J Foley 72 23 August 19, 1970—letter from Gerald J Foley to Detroiter Mobile Homes 73 24 January 2, 1971—letter from Gerald J Foley to Commodore Homes Limited 77 25 January 7, 1971—letter from Commodore Homes Limited to Gerald J Foley 79 26 January 8, 1971—letter from Gerald J Foley to Boise-Cascade of Canada Limited 80 27 June 23, 1971—memo from Gerald J Foley to Boise-Cascade of Canada Limited 82 28 June 28, 1971—letter from Boise-Cascade Mobile & Recreational Products to Gerald J Foley 83 29 January 22, 1971—letter from Gerald J Foley to Detroiter Mobile Homes 84 30 February 3, 1971—letter from Detroiter Mobile Homes to Gerald J Foley 85 31 January 22, 1971—letter from Gerald J Foley to Glendale Mobile Homes Limited 86 32 January 22, 1971—letter from Gerald J Foley to Great Northern Capital Corporation Limited 87 33 February 5, 1971—letter from Great Northern Capital Corporation Limited to Gerald J Foley 89 34 June 23, 1971—memo from Gerald J Foley to Great Northern Capital Corporation Limited 90 35 June 23, 1971—memo from Gerald J Foley to Northwest Design & Fabrication Ltd 91 36 June 24, 1971 — memo from Northwest Design & Fabrication Ltd to Gerald J Foley 92 37 June 23, 1971—memo from Gerald J Foley to Commodore Homes Limited 93 38 October 29, 1970—letter from Brock & Wyrzykowski to Gerald J Foley & Associates and attachments 94 39 April 6, 1971—letter from Brock & Wyrzykowski to Gerald J Foley 116 40 September 7, 1971—memo from Gerald J Foley to Donald C Brock 118 41 December 15, 1971—letter from Brock & Wyrzykowski to Gerald J Foley and enclosure 119 42 June 16, 1971—letter from Gerald J Foley to The Comax Corporation of Canada Limited and attachment 124 43 June 21, 1971—letter from Nozick, Akman & Associates to Brock & Wyrzykowski 127 44 September 25, 1972—letter from Gerald J Foley to Toronto-Dominion Bank 128 Argument The appellant argued that he had available to him the necessary funds for his plan, from the manufacturers of mobile homes, and that only delay and difficulty with zoning and other necessary approvals and permits prevented the fulfilment of the project. ...

He was a member of the partnership of E & B Cowan, Consulting Engineers, founded in 1945. ... I have found that this project has kept me young — I should have quit when I was 65 but I have found that working on this project has kept me young — it keeps me wanting to make sure that this happens and we are going to make it happen this year because we are working with a major company, a US company, this is the trouble up here you know we don’t think like they do down there, and we are going to build a demonstration plant in Alberta — a small mill — now the sulphite — the sulphite and sulphate — now sulphate is worse than sulphite, but the sulphite is something that you smell. ... Law — Case Law — Analysis 4.01 Law The provisions of the Income Tax Act involved in the present case are paragraphs 18(1)(a) and (b), 20(1)(t) and subsection 37(1). ...

Consequently, men and materials had to be carried by employees’ vehicles, including that of the appellant. 3.05 In addition to the written contract (Exhibit 1-1) which contains the following clauses: — Work outside of Quebec City: the salary remains the same and the expense allowance will be determined with the employers, — It is agreed that expense or allowance cheques will not be included in forms T4 and TP4, a verbal agreement was made setting use of the appellant’s vehicle for company purposes at $0.25 a mile. ... Mileage Total Total 1973 10,867 x 0.25¢ = $2,716.75 1974 14,633 x 0.25¢ = $3,658.25 1975 25,482 x 0.25¢ = $6,370.50 1976 11,194 x 0.25¢ = $2,798.50 3.07 In assessing the years 1973 to 1976, the respondent added the foregoing amounts. ...

The Appellant, before applying or receiving the grant hereinafter referred to, employed personnel as follows: Winnipeg — approximately 80 employees Toronto — approximately 10 employees Calgary — approximately 6 employees 5. ... Pursuant to the entitlement of $151,501.32 referred to in paragraph 7 hereof, the appellant received during its 1971 taxation year the following amounts calculated as follows: (a) in respect of approved capital costs — $18,114.00 (b) in respect of 31 jobs, 80% of the approved amount 76,880.00 $94,994.00 9. ...