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Each owned 33 / per cent of the shares (letters patent — Exhibit A-2). ... But that is what I do not understand: your responsibility in Emerillon — you had capital stock of $13,000.00 — was that your investment? ... Act — case law — analysis 4.01 Act The principal provisions of the Income Tax Act involved in the case at bar are 18(1)(a) and 20(1)(I) and (p). ...

The following are the addresses you request: Ruth & Co, c/o R I Hosp Tr Natl Bk, Box 1558, Providence RI 02901 Bull & Co, c/o Wachovia Bk & Tr Co, Box 3075, Winston, Salem NC 27102 Paine, Webber, Jackson & Curtis Inc, 25 Broad Street, New York, NY 10004 Galt & Co, New England Merchants Natl Bank, PC Box 4521, Tr Dept, Boston, Mass 02107 Hare & Co, c/o The Bank of NY, Box 11203, New York, NY 10249. Counsel for the appellant, at this point, referred to the reply to the notice of appeal (sic) and paragraph 5(a) thereof which reads as follows: the Appellant paid two registered holders amounts of interest as set out below and in so doing withheld (or deducted) and remitted to the Receiver General of Canada, tax purportedly pursuant to Part XIII at a rate of 15%, not at the rate of 25% established by Section 212(1): Amount Paid to Interest Interest Withheld & Registered Amount Amount Remitted Holder Gross Gross (at 15%) Hare & Co c/o Bank of New York New York, New York $4,875.00 $731.25 Paine, Webber & Co 25 Broad Street New York, New York $ 162.50 $ 24.38 He then stated as follows: And, if you turn to the reply to the Notice of Appeal, this is just to help the Board tie in to the assessment that has been made, in paragraph 5(a) of the reply, you will find that the figures there mentioned, which are the figures that tie into the assessment that is under appeal, relate to Hare & Co and Paine, Webber & Co, which is Paine, Webber, Jackson & Curtis, so that it would appear from that that the Department satisfied itself that the other three nominees were holding for US residents who owned beneficially, but Paine, Webber, Jackson & Curtis and Hare & Co were the two that, and I think my friend will know this better than I, I think simply didn’t respond to the enquiries made by the Department. ... Those two persons were: (a) Hare & Co c/o Bank of New York New York, New York; (b) Paine, Webber & Co 25 Broad Street New York, New York. ...

Mr Sammeroff explained that his firm determined, after considerable review, that the leased cars should be carried on the financial statements as current assets — inventory — as opposed to fixed assets — equipment used in a business. ... A certain segment of customers — the leasing clientele — would not have done business at Plaza unless they could have leased automobiles. ... The calculation of the profit of the company, according to the financial statements — if that were used for income tax determination purposes — apparently would not be in issue before the Board. ...

Mr Carson filed two financial statements relating to his law partnership — he has always been in partnership — and indicated that the criminal law practice provided a substantial source of income to the partnership. ... On page 2 he says: A $25,000 investment for / interest will give / of the net profit, plus / of the equity gained by reduction of the indebtedness of the Company plus / of any increase in value of the Hotel as a result of any increased turnover or inflation. ... That is where Mr Lloyd performed his function — in the licensed premises. ...

In support of the appeals this appellant submitted the following: Exhibit A-1 — a photograph of the subject property; A-2 — a photograph of Inland Cement Co property adjoining subject property; A-3 — a copy of a report by the Department of the Environment, Government of Alberta, Division of Pollution Control, for Check Realty Ltd dated May 6, 1971; A-4 — a copy of an agreement between Shell Canada Limited and Arthur E Kruger, made May 27, 1968; A-5 — a copy of an agreement between Art E Kruger, Donn Larsen and Elmer Duane Bassani, Pantel Holdings Ltd and London Properties Ltd of the First Part, and North American Road Ltd of the Second Part, made March 1, 1973. ... The dustfall levels detected were as follows: October 1970 — 85.4 tons/sq. mile/30 days November 1970 — 11.5 tons/sq. mile/30 days December 1970 — 26.4 tons/sq. mile/30 days January 1971 — 13.9 tons/sq. mile/30 days February 1971 — 36.5 tons/sq. mile/30 days March 1971 — 16.5 tons/sq. mile/30 days With the exception of the October 1970 level the dustfall levels were within the “Ambient Air Quality Standards” for the Province of Alberta. ... The appellant submitted the following exhibits: Exhibit A-7 — a photograph of the area surrounding the subject property; A-8 — a second photograph of the area surrounding the Subject property; A-9 — a copy of a document showing title to subject land, registered with the Land Titles Office in Edmonton, July 3, 1968. ...

. $190,000 X 1.159 acres — $220,210 $ 3,300 « 69 units. ■= $227,700 I consider that the value indicated by the per unit rate is most applicable in the subject case. ...

The reassessment was made and confirmed on the following assumptions of fact: (a) from 1974 to 1979 the Appellant owned one half of a tobacco farm comprising 235 acres of land; (b) in January, 1979 40 acres of the land were sold and in March, 1979, 148 acres plus buildings, equipment and marketing board rights were sold; (c) the Appellant incurred capital gains on the disposition of the land in 1979 calculated as follows: Proceeds of sale of 42 acres $ 40,000.00 Less: Cost 14,097.00 Less: Mortgage reserve: Capital Gain $ 6,476.00 Appellant’s share (50%) $ 3,238.00 Proceeds less disposal costs on sale of 148 acres $160,009.92 Less Cost 49,674.47 Less Mortgage reserve: Capital Gain $ 47,297.82 Appellant’s share (50%) $ 23,648.91 (d) the Appellant did not report any income from the sale of the farm land and assets in 1979; (e) on the sale of the land in 1979 the Appellant incurred a taxable capital gain of $13,443.46; (f) in February 1981 the Appellant acquired by purchase another tobacco farm comprising land, marketing board rights, buildings and equipment; (g) the Appellant did not file an election under subsection 44(1) of the Income Tax Act in his return of income for 1980. 3. ... Law — Analysis 4.01 Law The main legal provision involved in this case is subsection 44(1) of the Income Tax Act. ...

Soil Problems — Periodic climate drought aggravated by run-off where knolls are sharp. ... Soil Capability Rating — Class 4S indicating low moisture holding capacity and salinity. Crop Insurance Rating — J indicating a fairly high risk factor for Crop Insurance purposes. ...

In computing his income for 1974 the appellant claimed a capital loss of $7,442, which the Minister pleaded was calculated as follows:* [1] Proceeds of Disposition $201,000 Adjusted Cost Base $196,172 Outlays & Expense 12,270 208,442 Capital Loss $ 7,442 Allowable Capital Loss as above 3,721 In making the reassessment under appeal the Minister included a taxable capital gain of $12,038, which he pleaded was calculated as follows: Proceeds of Disposition $201,000 Less: Residence and one acre of land 46,650 $154,350 Less: V-Day value of property $150,000 V-Day value of residence and one acre of land 30,650 $119,350 Gain $ 35,000 Portion of Expenses Applicable: 154,350 x 14,225 201,000 $ 10,924 Capital Gain $ 24076 Taxable Capital Gain $ 12,0381 [2] Although the notice of appeal is unclear, it became apparent at the hearing that the issues in this appeal are issues of value and allocation which required determination of: A. the V-Day value of the farm, exclusive of the value of the principal residence, including such land as falls within that term by virtue of paragraph 54(g) of the Income Tax Act; and B. the portion of the 1974 sale price attributable to the farm, exclusive of the principal residence so defined. ...

The shares were transferred to the buyers after the payment. 3.14 Mr Farries’ approximate figures of the retained earnings in the company at different times were as follows: November 1970 — Incorporation $ 15,000 December 1971 — Buy-Sell Agreement 20,000 September 1974 — Departure of Mr Greenwood 100,000 3.15 During the years 1974 and 1975, the individual appellants received from the appellant company the following amounts, as the T-4 slips issued by the company show: 1974 1975 J K Farries $27,668.96 $93,192.11 R B Macpherson 26,570.47 81,989.09 F Fedor 24,284.43 $76,461.16 4. Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are 3, 5, 6 and 15. ... The fact that each one would own 75 shares (225 of Greenwood + 3) or more would not change the right to the approximate one third (375/1,000; 300/1,000 and 325/1,000) of the remaining retained earnings. ...