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It was alleged by the Minister that: — at all material times the appellant was closely involved in the operation of the various businesses of E L Morash and operated them when he was away attending other business interests; — beginning in 1974 the appellant made small regular deposits of cash to accounts at Central and Eastern Trust Company and its predecessors; — the appellant at all material times had signing authority with respect to Mr Mo- rash’s businesses; — the deposits totalling $36,998.43 represented income from the businesses with which the appellant was associated; — the appellant in 1977 had an apparent net worth totalling $170,603 composed of the following: Cash and GIC’s $ 82,603 Residence 65,000 Furniture 15,000 Vehicle 8,000 $170,603 — the appellant had no liabilities in 1977. ... The appellant contended: — she had inherited some money from her late husband and realized further amounts from the sale of furniture from her Toronto home. — she had kept substantial amounts of cash at home and deposited amounts in the bank only as required for particular expenditures. ... At no time was she in business for herself as an owner or principal. — she had agreed to lend money to Mr Morash as he required for business purposes, and these loans were frequently made and frequently repaid. ...

The following are the facts presumed by the respondent: — The appellant was employed by La Compagnie Loram-Komo Opinaca as an assistant project manager on the Petite Opinaca project at James Bay; — The appellant received from his employer as a remoteness premium an allowance of $270 per week, for a total of $14,040 In the 1979 taxation year; — the appellant was fed and lodged at the expense of his employer; — the appellant’s employer had made available to the appellant accommodation at the very place of his employment. ... Every unit installed at Eastmain shall be approved by la Société d’énergie de la Baie James and conform to the special standards following: — heating shall be done by means of fuel furnaces and forced ventilation ducts, — all exterior coating shall be of steel and painted with a baked enamel finishing, — the fire prevention shall be carried out by heat or smoke detectors giving a local alarm and by portable chemical extinguishers, — piping, plumbing and electric wiring shall conform to the Regulations of the Province of Quebec and Contractor shall submit to Energy, upon request, the drawings approved by the authorities having jurisdiction, — a 12 ft by 8 ft shelter may be built at the unit entry, — any additional construction shall be approved by Energy. ... Both counsel provided the Board with summaries of the relevant legislation, case law and definitions, and submitted the following references: — Kenneth W Blackman v MNR, [1967] Tax ABC 480; 67 DTC 347 p 1; — Ferguson v Noble, 7 TC 176; p 6; — Gilles Lépine v MNR, [1978] CTC 2895; 78 DTC 1637; p 12; — The Queen v Morton Pascoe, [1975] CTC 656; 75 DTC 5427; p 16; — Ricketts v Colquhoun (1925), 10 TC 118; p 18; — J R Scanlan v MNR, 3 Tax ABC 329; 51 DTC 84; p 38; — WA A Sheaffer Pen Company of Canada Ltd v MNR, [1953] Ex CR 251; [1953] CTC 345; 53 DTC 1223; p 39; — Graham L Harle v MNR, [1976] CTC 2203; 76 DTC 1151; p 48; — Télesphore Demers v MNR, [1979] CTC 3132; 79 DTC 917; p 53; — The Queen v Télesphore Demers, [1981] CTC 282; 81 DTC 5256; p 57; — “Pension” (board), Dictionnaire alphabétique et analogique de la langue française, Volume 5, LE ROBERT, 1972; p 61; — “Board” The Shorter Oxford English Dictionary on Historical Principles, Volume 1, A-M, Oxford; p 63; — “Board” Words and Phrases Legally Defined (2d), Volume 1, A-C, Butter worths, 1969; p 65; — “Lodger”, Words and Phrases Legally Defined (2d), Volume 3, I-N, But terworths, 1969; p 67. ...

The basic facts as outlined by the appellant were: — the taxpayer was invited to Japan by the Nisson Automobile Company (Canada) Ltd (Nisson) to view the manufacturing facilities of that company. The trip in respect of costs and time spent in Japan was entirely of a business nature. — the taxpayer acknowledged that some portion of the expenses ($550) is of a personal nature. — The benefit deemed by the Minister to be taxable is excessive. The contentions of the respondent were: — that the appellant was the (part) owner of a Datsun Dealership (Southside Datsun Ltd of Vancouver, British Columbia); — that Nisson Automobile Company (Canada) Ltd was the appellant’s supplier and that in 1977 Nisson gave the appellant a trip to Japan; — that the trip to Japan was a personal benefit to the appellant, and that no part of the trip involved business activities. ...

Rempel was in the construction business and in 1967 incorporated H & D Investment Limited. ... The sequence of events was as follows: December 22, 1972— — Bank loan to taxpayer, H J Rempel $60,000 —Savings account opened in name of taxpayer, H J Rempel with deposits of $60,100 —Withdrawal from savings account $60,000 January 5, 1973— — Deposit in savings account $60,000 — Withdrawal from savings account $60,000 — Repayment of bank loan $60,000 (i) The securities on which the taxable capital gain was realized in 1972 were registered in the name of the Appellant, were purchased by the Appellant, were sold by the Appellant, and were beneficially owned by the Appellant. ... Journal entry # 43 represented transactions by Rempel in December 1973. ...

I have identified each property with a letter, given a brief description of it and its general relative position with regard to the subject property, together with the numerical identification indicating which appraiser(s) used it: 1971 Inside Date Date Price Relative Identi Town Acreage of per to Appraiser Used by fication Limits Size Sale Acre Subject 1 2 3 4 Appraisers A X 10 4/73 $ 600 NW % mile X 37 B X 160 NW 1 mile X 9/76 3500 C x 18 3/73 1915 NW % mile X X D X 5 9/73 5000 W /2 mile* XX 3 E X 2 9/73 2190 W / mile X F X 5 11/73 6000 W ’/ mile XX 3 G 219 4/72 426 SE adjacent X X 2/4 H X 70 11/69 571 NW % mile X I 70 7/72 457 E. adjacent X X 2/4 J X 20 10/70 850 NW % mile X K X 28 11/73 750 NW ’/ mile X L X 9 3/73 1235 NW % mile X M X 29 11/72 637 NW /2 mile X 4 — In or adjacent to built up areas of Brooks. ... So, at most — sorry — at best, we are dealing with an immediate need, no lots available, and of course there was a one-year supply of lots, if we believe Mr Braa’s testimony. ... Leaving these comparables (“G” and “I”) out of the reports of Pro and Zezulka indicates that in the authors’ minds, no importance whatsoever should be attached to the selling price of the properties — $426 and $457 per acre by them, at a time only months removed from V-Day — a view which I do not espouse. ...

The said $24,000 was paid to A Pawlowski & Sons Limited in 1973 by Kaiser. ... A Pawlowski & Sons Limited never billed Kaiser for any such services. ... The appellant had the major control of A Pawlowski & Sons Limited which gave him the right to act as he pleased. ...

The context of the appeal is evident from the pleadings filed by the appellant: — In 1977 Fambeau Limited sold the properties for a total consideration of $622,750. — The company estimated that the aggregate value of these properties as at December 31, 1971 was $650,000. ... Tonin’s position that it had absolutely no effect whatsoever is simply incredible and, therefore, I think it completely — that kind of position — completely undermines whatever other testimony that he had to give in this particular case. ... As a layman walking down the street, one would anticipate — as my friend has submitted to you you should, you should take judicial notice of it — that a big, booming, brand new development is going to have some impact on the surrounding area. ...

Income Tax Act, RSC 1952, c 148 — 54(2) — Interest. The appellant deducted from his remittance of tax for 1969 (1) an amount levied as interest, and (2) an amount he claimed was an overpayment of tax in 1968. ... Income Tax Act, RSC 1952, c 148 — 85B(1)(d) — Special reserves — Real The appellant was incorporated in 1959 as a construction company and on the strength of borrowed money proceeded to erect an apartment building. ... The formula then becomes: Gross Profit,... x Amount of receivable — reserve Gross Selling Price less Mortgages Assumed In the instant matter, the evidence was that the modified formula was used. ...

In making its returns of income for its 1972, 1973 and 1974 taxation years the appellant claimed capital cost allowance under class 10 and class 6 of schedule B to Income Tax Regulation 1100 as follows: 1972 1973 1973 1974 1974 Class 6 $ 42,165.47 $ 58,624.29 $ 60,235.39 Class 10 $381,977.82 $600,252.15 $594,286.50 3. In re-assessing the appellant for the taxation years under appeal, the respondent determined that certain of the capital assets which had been classified by the appellant to class 10 should have classified as class 6 and accordingly capital cost allowance was allowed the appellant as follows: 1972 1973 1973 1974 1974 Class 6 $ 60,568.29 $101,297.69 $132,658.03 Class 10 $326,769.11 $483,423.43 $417,176.40 4. As a result of the said re-assessment, the net income of the appellant was increased for the years under appeal by the following amounts: 1972 $ 36,805.89 1973 $ 74,155.32 1974 $104,687.46 The basic question is whether some one hundred and five so-called “trailers” owned by the appellant come within the meaning and intent of property falling under class 10 of Schedule B to the Income Tax Regulations permitting a deductible allowance of 30% claimed by the appellant or whether the property comes under class 6 of Schedule B where the deductible allowance of 10% as claimed by the respondent in his reply to the notice of appeal. ...

At the time of the transaction Mr Fred Berman was the general manager of Commercial Steel & Metals Ltd. ... Canada Trust is the registered owner of one sixth of the isued shares of Commercial Steel & Metals Ltd. 2. ... Mr Fred Berman gave the history of Commercial Steel & Metals Ltd and an idea about its assets. ...