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John made all or virtually all of the mortgage payments — including the Canada Permanent mortgage. ... There remained then the $80,000 WIRA mortgage — barely equal to the total of the Wunder and Pax mortgages. ... I am sure that Margaret stated the situation correctly as she recalled it — she would only agree to sell Galt property if she could get the Paris property (at least her roughly / of it) in return. ...

It was a much larger investment firm than Garneau & Associates Inc and offered a great future in the eyes of the appellants as the offer was presented to them. ... It is entitled “Fifteenth Amendment to Partnership Agreement of J R Timmins & Co”—a copy of which was filed as Exhibit A-1. ... A copy of the said agreement was filed as Exhibit A-2 and is entitled “Sixteenth Amendment to Partnership Agreement of J R Timmins & Co.”. ...

On December 12,1975, he placed an order with his investment dealer A E Ames & Company (“Ames”) to purchase $30,000 of Government of Canada Bonds (“Bonds”) at 7 /4%. ... Contentions By the appellant: — Physical delivery of the bonds to me was made by Ames against full payment on December 12, 1975. ... —The bonds were disposed of on December 15, 1975 by redemption. — I received an interest payment of $1,087.50 on account of the ownership of the Said bonds. ...

. — In 1963, he purchased from his father a long narrow strip of land which was Cut in two by the main road running through Kippens. On the one portion of the thus divided strip of land he built his home. — He is reasonably well educated, and had several job offers, including positions in Montreal and Cornerbrook, but he did not want to reside away from Kippens. — In 1972, using almost all of his savings, he purchased from relatives (who had inherited it from his father) an additional strip of land adjacent to part of his original property. ... —The appellant obtained employment at the linerboard mill in Stephenville, and remained living at his home in Kippens. — In the years 1973 and 1974, he was approached by fellow employees, first enquiring who owned the property in question, and ultimately asking to purchase building lots. — Having decided to sell some of the property by 1975, he cleared some land, put in an access road and prepared a subdivision plan. ...

Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are 153(1)(a), 227(8), 227(9) and 227(10). ... It is really a salary, and not a gift as it is contended in the Coopers & Lybrand Limited case. ... The Board finds that the numbered company was in the same situation as Venus company in the Coopers & Lybrand Limited case. ...

The respondent, in the reply to notice of appeal, contended: — The appellant was employed by Can-Val from July of 1974 to sometime in 1977; — In 1978 the appellant received from his former employer remuneration in the amount of $11,383.50 as a deferred bonus based on the employer’s earnings from 1974 to 1977; — The said deferred bonus was paid to the appellant in 1978 by his former employer pursuant to a contractual arrangement between the employee and employer, the terms of which are set out in the agreee- ment; — On February 1, 1977 the appellant purchased an income averaging annuity contract; — In reporting his income for 1978 the appellant claimed a deduction (for the amount in question) pursuant to section 61 of the Income Tax Act; — The deferred bonus referred to and paid into the said income averaging contract was on account of remuneration from employment. ... According to Mr Hoyt, he could not have had “longer service” with Can- Val — he had been with the company right from its beginning. ... I am not certain that would be a point to be considered fatal to his case — because it would raise a question regarding the length of service necessary before a resignation would be effective as retirement. ...

It was also admitted that at all material time R & M Heating Ltd had only one employee, the appellant. ... It named the trustees for the plan and provided for the coverage of additional employees of R & M Heating Ltd. ... R & M Heating Ltd had and still has only one employee, the appellant. 3. ...

This was with the goodwill, of course, of — well, they couldn’t do anything about it anyway — of the firm. ... Accounting, legal, collection $ 212.50 2. Advertising, promotion 897.69 3. ... Professional subscriptions & dues 321.75 TOTAL $7,022.43 Add: Capital cost allowance © Total expenses (deduct from “Gross Income”) 7,022.43 Excess of income over expenses $ 3,470.29 3.08 Other details were given concerning each item. ...

However, Mr Panchyshyn qualified the above evidence later by stating — “I’m under oath and I just can’t swear that it was $48,000”. ... He further testified, as follows: that — I wanted to take Alec along just for — so that he would hear what Mr Brooks had to say, how much I! ... In fact it is difficult to sell land at the present time — at any price. ...

Lot Block Dist Lot Plan PURCHASE PRICE OF: 1 & 2 49 548 STREET CITY OF ADDRESS 1450 Chesterfield Avenue (18 Ste apt Bldg) North Vancouver, BC THE PRICE OR SUM OF FOR: Two Hundred & Thirty Five Thousand Dollars $235,000 Payable on the following terms, namely (Cash) Two Hundred & Five Thousand Dollars 205,000 Of which the deposit shall form part. ... Argument On the main point at issue, the favourable points, according to counsel, were that the appellant: — in order to purchase the building, took out a five-year mortgage with a substantial penalty clause for early payment; —took out a second mortgage at an atrociously high interest rate—18% per annum; — renovated several of the suites, did work on the heating system and the furnace room; — put in an office just off the lobby; — brought her sister from Toronto, out of a secure employment position to help her run the building; — moved into the building herself with her fiance; — rented suites in November 1973, for which on registration under STA she had to pay the residents a penalty. ... There was (simply) an avenue available to her that Mr Carp persuaded her she should keep there.” —. ...