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That amount was regarded by the respondent as that portion of the income of an accounting firm known as Laventhol Krekstein Horwath & Horwath (hereinafter called LKH & H) for the fiscal period from January 29, 1972, to January 5,1973, which was allocated to the appellant by agreement of the partners of the LKH & H firm. ... The appellant’s evidence was that when he left LKH & H he entered into an agreement with the firm, later reduced to writing (Exhibit A-1). ... I observe that upon the apellant’s entry and departure from the LKH & H partnership goodwill was not recognized. ...

Now, what I do with that — that’s one of the assistant director’s main tools — is I move each scene around and I put together days of shooting and eventually weeks of shooting. ... I might mention that from the point of view of Westminster Films, we have about six (6) people on staff — secretaries, receptionists, office managers, a couple of producers — and everybody else is freelance. ... Stevenson, Jordan and Harrison Ltd v MacDonald & Evans, (1952) 1 TLR 101; 28. ...

Contentions For the appellant: — The promissory note represented a debt which was acquired by the appellant for the purpose of gaining or producing income from a property. — The promissory note had become a bad debt in 1977. — The promissory note held by the appellant was enforceable but worthless and remains so on this date. ... He was to recover his interest costs by the income from his investment — albeit both of them at the same rate. ... Counsel referred the Board to a recent decision — Robert G Cantin v MNR, [1981] CTC 2918; 81 DTC 811. ...

One of the figures appearing in this document is “Cost of House — $35,309.85”. ... The abstract of title for the two cottage properties at Mineville, Halifax County, Nova Scotia, is as follows: Warranty Deed Lake Echo Forest Park Limited 2975/24 — to — August 21, 1974 Leonard P Carrigan and wife, January 13, 1976 Margaret Theresa Anne Carrigan, $1.00 as Joint Tenants Warranty Deed Lake Echo Forest Park Limited 2975/28 — to — August 21, 1974 Leonard P Carrigan and wife, January 13, 1976 Margaret Theresa Anne Carrigan, $1.00 as Joint Tenants Warranty Deed Leonard P Carrigan and wife, 3122/473 Margaret Theresa Anne Carrigan, June 7, 1977 — to — June 10, 1977 Margaret Theresa Anne Carrigan, $1.00 The abstract of title for the family home at 15 Charlois Court, Dartmouth, Nova Scotia, is as follows: This document clearly sets forth the dealings with the properties at issue in this appeal. ... Warranty Deed Glendale Building Company Limited 2707/440 — to — August 23, 1973 Lake Echo Forest Park Limited September 27, 1973 $1.00 Warranty Deed Lake Echo Forest Park Limited 2771/296 — to — September 28, 1973 L P Carrigan April 8, 1974 $1.00 Warranty Deed L P Carrigan 2824/166 — to — August 23, 1974 Leonard P Carrigan and wife, August 29, 1974 Margaret Theresa Anne Carrigan, $1.00 as Joint Tenants Warranty Deed Leonard P Carrigan and wife, 3122/992 Margaret Theresa Anne Carrigan, June 7, 1977 — to — June 13, 1977 Margaret Theresa Anne Carrigan $1.00 What, then, was the value of 15 Charlois Court on August 23, 1974 and on June 7, 1977? ...

Lot #314 Mr & Mrs Leo Paquette (Sept. 10, 1965 1,500.00 178.00 4. ... Lot #352 Erkki J Vilen & Selja Vilen (9. Lot #353 Erkki J Vilen & Selja Vilen (10. ... Lot #348 Martti Luhtala & Sarnia Luhtala Aug. 7, 1969 1,500.00 12. ...

The amount in dispute arose from the filing with the Minister of a Form T2049 “Agreement In Respect Of Unpaid Remuneration”, authorized under subsection 78(3) of the Act, by a company, TH & S Electric Limited (“TH & S”), for the 1973 taxation year. ... The appellant stated in his oral testimony that previous to that acquisition, he had no association with TH & S in any way. ... Further, when that testimony is accepted, the rationale and explanations provided by Yale & Partners (supra) are irrelevant and misleading. ...

Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act and the Income Tax Regulations involved in the present case are section 30 of the Income Tax Act and Clas 8 of Regulation XI, passed pursuant to paragraph 20(1)(a) of the Act. ... The cost of a paved road is not fully deductible in the year but is subject to capital cost allowance under Part XI (Class 1) — see Chapter 3. If you own land that is rented to a tenant and if you pay for constructing a road or installing tile drainage and have not previously charged these costs as expenses, then you may claim capital cost allowance under Part XI (Class 1 — 4%, if acquired before May 26, 1976; Class 17 — 8%, if acquired after May 25, 1976) on the cost of constructing the road, and (Class 8 — 20%) of the cost of tile drainage. 4.03.2 The Board shares the opinion of the respondent’s counsel. ...

Law — Precedent Cases — Analysis 5.01 Law The main section of the Income Tax Act involved in the present case is paragraph 109(1)(a) which reads as follows: For the purpose of computing the taxable income of an individual for a taxation year, there may be deducted from his income for the year such of the following amounts as are applicable: (a) in the case of an individual who, during the year, was a married person who supported his spouse, an amount equal to the aggregate of (i) $1,600, and (ii) $1,400 less the amount, if any, by which the spouse’s income for the year while married exceeds $300; 5.02 Precedent Cases The appellant referred to the following cases: 1. — Percy Walker Thomson v MNR, [1946] CTC 51; 2 DTC 812; 2. — Roderick W S Johnston v MNR, [1948] CTC 195; 3 DTC 1065; 3. — Frank Wesley McKee v MNR, 25 Tax ABC 8; 60 DTC 443; 4. — No 502 v MNR, 19 Tax ABC 40; 58 DTC 164; and, 5. — William Buzsik v MNR, 12 Tax ABC 285; 55 DTC 165. 5.03 Analysis 5.03.1 The requirement of paragraph 109(1)(a) that the taxpayer must support his spouse during the year is regarded as meaning “in the course of the year” and not as meaning “throughout the year” so that support for any length of time, however small, will qualify for exemption in the case of persons marrying near the end of the calendar year (P W Thomson v MNR, (supra), and L W F H Cooper v MNR, 29 Tax ABC 294; 62 DTC 339). ...

I am requesting that the 90-day time limit for filing an objection be waived since the notices of objections weren’t filed earlier for the following reasons: — I do not speak English fluently and I wasn’t notified by the tax auditors of the 90-day time limit for filing a notice of objection. — I didn’t engage an accountant until after the 90-day period had expired. — I subsequently contacted Revenue Canada and they suggested that I send them a letter requesting that they accept adjustments to the reassessments rather than file a formal notice of objection. — I sent a letter dated September 30, 1977, requesting the department to review the reassessments and in January 1978 they notified me that they would accept any additional information relating to the reassessments. — I reviewed my records and found that I previously hadn’t taken capital cost allowances that I was entitled to but after the reassessments it would be to my benefit to claim the capital cost allowance. — I submitted a letter dated March 31, 1978, requesting that the capital cost allowance claim be amended. — Revenue Canada notified me July 24, 1978, that they wouldn’t amend the capital cost allowance because I had passed the 90-day time limit and said that I would have to file a formal notice of objection to the reassessments if I wanted the capital cost allowance claim allowed. ...

I don’t remember the intent to form an operating company. 3.23 The respondent, on June 10, 1977, issued notices of reassessment for the taxation years 1973 and 1974 increasing the net income as follows, as it appears on form T7WC annexed to the notices: 1973 1974 1974 Previous net income $ 1,540 $ 9,277.70 Commissions and fees purportedly earned by Vacatia Limited $146,965.72 $ 7,313 Minus commissions expense related thereto, not previously claimed $ 29,811.25 ($488) TOTAL $117,154,47 $ 6,825 Plus: interest income purportedly earned by Vacatia Limited $ 2,451 $3,782 Plus: Value of Red Island transferred to wife of principal shareholder $ 9,000 Minus increase in allowable CCA schedule attached ($3,799: Revised net income $130,145.47 $16,085.70 Revised taxable income $130,145.47 $16,085.70 3.24 On September 6, 1977, the appellant filed a notice of objection. ... It was on March 6, 1978, that changes appeared as follows on form T7WC annexed to the notices: 1973 1974 Previous net income $130,145.47 $16,085.70 To transfer previous adjustment re Whitehead from 1973 to 1974 fiscal period $ 27,750 $27,750 fee purportedly earned by Vacatia ($ 9,011.25) $ 9,011.25) less: related commission expense $ 18,738.75 $18,738.75 To reduce the fair market value of Red Island from $9,000 to $2,500 $ 6,500 TOTAL $ 25,238.75 $34,824.45 Revised net income $104,906.72 $34,824.45 Revised taxable income $104,906.72 $34,824.45 4. ... Alberta & Southern Gas Co Ltd v Her Majesty the Queen, [1976] CTC 639; 76 DTC 6362; [1977] CTC 388; 77 DTC 5244; 6. ...