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Mr Mottershead said that the appellant owned 50% of the shares of Francis M & A Holdings Limited (“Holdings”), which shares were valued at approximately $82,000 at book value. ... It would seem that where powers are granted to some authority, as in Bawtinheimer v Niagara Falls Bridge Commission and Thames (River) Conservators v Smeed, Dean & Co., the courts are likely to hold that the special provision is additional. But where a special procedure or modus operandi is prescribed for a special case, as in Blackburn v Flavelle, the courts are likely to regard it as exclusive, on the same principle that a codifying statute is regarded as exhaustive, 51 namely, that the legislature has manifested an intention to create a complete legislative code governing the subject-matter. 50 See R v Eastern Archipelago Co (1853), 1E & B 310; 2 E & B 856. 51 Bank of England v Vagliano Bros, [1891] AC 107. ...

However no evidence was produced as to the efforts made by the appellant company to have the plan approved, nor was there any indication that the city had refused to approve the plan. 7 On October 19, 1971 the appellant company forwarded another $1,000 to A & W for a further extension of its offer to purchase but this amount was not accepted by A & W (Exhibit A-5). 8 Also on October 19, 1974 Trojan Industrial Properties Limited (hereinafter referred to as “Trojan”) made an offer to purchase the land at McLeod Trail and 94th Avenue SE from the appellant company for $250,000—which offer was accepted by the appellant company (Exhibit A-6). 9 On October 28, 1971 the appellant company forwarded to A & W a cheque for $39,500, being the balance of the down-payment on the purchase of the McLeod Trail property which was not accepted by A & W (Exhibit A-7). 10 On October 28, 1971 a caveat forbidding registration of the McLeod Trail property was filed by the appellant company (Exhibit A-9). In a letter of October 29, 1971 (Exhibit A-8) A & W's solicitors, on the assumption that Richfield Real Estate Ltd and Mr Brad Calvin, who had been acting on behalf of A & W had business interests with the appellant company, and particularly in connection with the proposed sale with Trojan, stated that A & W was no longer prepared to grant possession of the McLeod property unless a statutory declaration was signed by Messrs Calvin and Kitzul that no such business interests existed between them. ... Because of A & W's interest in the property, the appellant company could not, by itself, effectuate the sale to Trojan. ...

Thomas Summerson & Sons Limited, [1926] 1 K.B. 131, 9 TC 577, which was followed in No 729 v. ...

In October of 1966, the Appellant, together with others agreed to invest certain monies in a private company called Columbia Auto Rentals & Services Limited (“Columbia”). ... Income Tax Act, RSC 1952, c 148 — 4, 5(1)(a), 16(1) — Indirect payments — The appeal concerned amounts of $2 and $26.80 added to appellant’s income as contributions made on his behalf to an insurance plan. ... After examining the return, respondent raised the net income for the year to $6,380.76, as shown by Form T7W-8, set out below: Net income reported $5,411.45 Add: Contribution to ACTRA Insurance Plan on your behalf by Canadian Marconi Company $ 2.00 Contribution to Actra Pension & Insurance plans on your behalf by The National Film Board 26.80 28.80 Expenses disallowed: Telephone & Telegrams $ 65.00 Rental-office 250.00 Selling expenses 240.00 Transportation 390.00 945.50 $6,385.76 Deduct: Error in expense claimed 5.00 Net income assessed $6,380.76 section 12(1) of the Income Tax Act, RSC 1952, c 148). ...

. — The business of the partnership was the development of a racquet club in Richmond Hill. — The Appellant and his partners each spent a considerable amount of time working on the development of such a facility but ultimately discontinued the business on June 1, 1978 after the partnership failed to obtain permits from the Town of Richmond Hill for such a facility. — The partnership incurred a loss of $10,124 in the fiscal period ended June 30, 1977. ... Notwithstanding the contentions of counsel for the appellant, it is my view that the reverse is the situation in this appeal — “Richmond Hill Squash Club” was not a “business” to operate and earn income from a squash club — but only to investigate the feasibility of doing so. ... But the amounts involved, if deductible at all, would be deductible from the income — if any — of the corporation(s) in the circumstances of this case. ...

. — On May 20, 1975, the appellant shareholder(s) received a loan from Morris in the amount of $24,746.33; — During his 1975 taxation year, the appellant was a shareholder of Morris by virtue of being the registered holder of one share; — The purpose of the loan was to enable the appellant to purchase a building situated at 8215 Champ d’Eau in the City of St Leonard, District of Montreal; — The lending of money did not form part of Morris’ ordinary business; — On November 30, 1976, the said loan in the amount of $24,746.33 was repaid to the lending company, and on the same day, Morris reloaned the same amount of $24,746.33 guaranteed by a mortgage in favour of the lender, Morris. The position as outlined by the appellants was: — The taxpayer(s), in 1975, (each) owned 50 per cent of the issued and outstanding common shares of SERIT HOLDINGS LIMITED (“Serit”). — Serit owned (and continues to own) 96 of the 100 issued and outstanding common shares of Morris. ... Contentions For the appellants: — The taxpayer(s) was not a “Shareholder” of Morris. ...

The facts set out in paragraph 6 of the reply to the notice of appeal are admitted and read as follows: In assessing the appellant for the 1975 and 1976 taxation years, the respondent relied, inter alia, on the following presumptions of fact: (a) by notarial deed dated August 1, 1962, Dame Marguerite F Doriga ‘gave, as a trust donation to Les Fiduciares de la Cité du District de Montréal Ltée’, a number of securities, ‘securities which the Trust admits it has received and taken in trust for the following purposes: — to pay to the said Marguerite F Doriga, for the rest of her life, the income form the above-mentioned securities’; (b) during the years under dispute, the appellant resided in Canada; (c) during the entire period under dispute, Dame Marguerite F Doriga resided in Spain; (d) in accordance with the trust deed referred to in subparagraph (a) of this paragraph, during the 1975 and 1976 taxation years the appellant paid Mrs Doriga $11,744.14 and $14,512.07 respectively; (e) the appellant neglected to withhold and submit to the Receiver General, in the name of Dame Marguerite F Doriga, the amounts of $898.08 and $2,980.85 as income tax payable by the said beneficiary. ... He referred the Board to the following decisions: List of authorities A — DWN N Walters, Law of Trust in Canada, pp 4-6; B — Canadian Income Taxation of Trust. Fiscal Definition of Trust, pp 7-12; C — Quinn v Leathen, [1901] AC 495; D — J N O’Meara and others v Bennett and others, [1922] AC 80; E — Dame Eleonore Curran v Meyer Davis, [1933] S.C.R. 283; F — Laverdure v DuTremblay, [1937] AC 666; G — Guarantee Trust of New York v The King, [1947] S.C.R. 183; H — No 199 v MNR, 11 Tax ABC 353; [1954] DTC 488; I — Charles Glass Greenshields v The Queen, [1958] S.C.R. 216; J — Redford v National Trust Company and Dame Maclnness, [1968] QB 689; K — Income Tax Act, 1972, ss 483 to 523; L — Higher et al v Crown Trust Company, 5 NR 561; M — Joseph Morris v MRQ, [1975] CP 250: N — The Queen v Littler, [1978] CTC 235; 78 DTC 6179. ...

C.R. 308, [1967] C.T.C. 165, 67 D.T.C. 5114, in which Cattanach, J adopts the opinion expressed by Locke, J in Sutton Lumber & Trading Company Limited v Minister of National Revenue, [1953] 2 Ex. ...

The list did not include all the properties managed by Murdock & Maber Agencies Ltd. (hereinafter referred to as “Murdock & Maber”). The appellant contends that the expenditure of $30,000 made by it for the purchase of the list of property management accounts from Murdock & Maber was an expense properly deductible from income and should not be considered in any way as a capital outlay or as an “eligible” capital expenditure. ... All of the accounts in the list provided by Murdock & Maber required approaching the owners and the negotiating of new contracts by the appellant. ...

It would range between — that particular year it ranged between 5 and 11. ... The children, the supply — of course they are transported by buses, but the buses do not stay and I have always taken my car there in case of illness or in case of an emergency trip to the hospital. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are 8(1)(h), (j) and (2). ...