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If the respondent is correct, the taxable capital gains would be (1) Mr Georges Bouthiette —$57,973; (2) Léon Tétrault & Fils Inc —$52,500. If the appellants are correct, the taxable capital gains would be (1) Mr Georges Bouthiette —$27,000; (2) Léon Tétrault & Fils Inc —$22,000. As will be seen, the appellants sold their pieces of land 15 /? months after Valuation Day and 22 months after the purchase. ...

. — The company hereby appoints Mr Jones, and undertakes to have him appointed by Tabacs Trans-Canada Ltée, exclusive agent for the pur- chase and supply of leaf tobacco, at the best possible price in view of market conditions. 2. — The company further undertakes to appoint Mr Jones, and have him appointed by Tabacs Trans-Canada Ltée, technical adviser with the right to be present at the directors’ and shareholders’ meetings of both companies. 3. — Both personally and in his capacity as president and majority Shareholder of F H Jones Tobacco Sales Co Ltd, Mr Jones undertakes to Supply the company and Tabacs Trans-Canada Ltée with leaf tobacco, at the best possible price regard had to market conditions. 4. — In addition to the guarantee in respect of the loan of $200,000 provided by Mr Jones, the company undertakes to deposit as collateral security the controlling shares in Tabacs Trans-Canada Ltée purchased with the proceeds of the loan, as well as the shares held personally by the directors of the Company in their own company, and any shares which the latter shall acquire in the said company. 5. — Further, subject to the additional guarantees contained in the preceding paragraph, the company undertakes on its own behalf as well as that of Tabacs Trans-Canada Ltée, not to make any capital expenditures or loans other than bank loans without the consent of Mr Jones so long as the latter’s personal commitment remains in effect. Similarly, the salaries of the executive officers of both companies shall not exceed the sum of $40,000 per annum overall. 6. — In the event that the company merges with Tabacs Trans-Canada Ltée it is agreed that the merged company will have the same obligations towards Mr Jones as the two aforementioned companies. 7. — Mr F H Jones’ guarantee will be provided by his endorsement of one or more promissory notes for a total amount of $200,000. ... Before concluding I would cite the following cases: L Berman & Co Ltd v MNR, [1961] CTC 237; 61 DTC 1150, a judgment of the Exchequer Court; Heap and Partners (Nfld) Ltd v MNR, 42 Tax ABC 278; 66 DTC 772; MNR v The Kellogg Company of Canada Ltd, [1943] S.C.R. 58. ...

It was contended by the respondent that: — the appellant incurred no capital loss in its 1975 taxation year; — the amount of net capital loss available to the appellant to carry back to its 1974 taxation year was nil. ... There is, however, a new factor in the instant case which warrants re-examination — that upon which the entire casé of the appellant is founded. ... While the sale of shares would normally be a “... transaction or event entitling a taxpayer to proceeds of disposition...” ...

While Mrs Shirley was peacefully sitting holding her 20-acre parcel of land located immediately to the south of the City of London, the St Lawrence Cement Co — acting completely on its own initiative — made application to her early in 1967 for a right-of-way across her said property for the purpose of connecting its property (which lies to the south and west of Mrs Shirley’s property) with the CNR line running from London to Port Stanley by constructing therefrom a spur line on the proposed right-of-way. ... The company’s liabilities, endorsed by the father, were as follows: $1,580.21 — overdraft for NSF cheques 40,000.00 — bank loan 36,972.63 — mortgage on the new building 20,990.83 — trading account According to a 1965 record, $88,370.59 represented the amount that the company owed the father as at the end of 1965. ... Counsel for the appellant argued that Mr Atkinson, Sr’s business was a three-pronged affair — law, lending money and dealing with Risteen and other companies; that he used them indiscriminately, and that it would be unfair to segregate one from the other because it was a one-man affair. ...

Regarding the difference between our agreed rent and the mortgage payment, which I am paying direct — rather than sending it to you and then you sending it back to Royal — I will settle that up in the future hopefully. ... I don’t have all of the receipts but will keep all future ones — that’s for sure. ... I told her that I thought that you wouldn’t want to rent to just anybody — after all, you bought the place as an investment, and if the tenant (new — that is) wasn’t a good one — you might lose money in future repairs and so on. ...

Jacot’s understanding of the arrangement was that profits would be divided on a 50/50 basis with the appellant — if there had been profits. ... The appellant’s contention is that this was a venture in the nature of trade — a business — that the 1% return from MPIM was the potential source of earning to which he can point. ... It is quite possible to believe that the Minister would have regarded the 1% return to the appellant as a gain or profit from the sale of a property — a return on the disposition of an asset acquired for the sole purpose of sale — a business purpose clearly. ...

In so assessing the Minister of National Revenue disallowed expenses claimed in the following amounts: 1975 — $3,521.31; 1976 — $9,268.59; 1977 — $9,116.03. ... Artistic production — including writings, musical, dramatic and cinematographic works. ... Every relationship, whether “employment” or “business”, is founded on some form of contract — written, oral, explicit or implied — and it is to the terms of the contracts available in this matter that the Board must look for guidance. ...

The opening balance sheet of Services Farmico Inc, dated June 26,1973, reads: Assets Cash $2,000 Share Capital Authorized 50,000 no par value shares Issued and Fully Paid 200 shares $2,000 A year later, on May 31, 1974, the balance sheet of Services Farmico Inc read as follows: Assets Current assets Bank $115,723.54 Royalties receivable 65,307.24 181,030.78 Capital assets—at cost Accumulated Cost depreciation Equipment $28,554.54 $ 5,710.90 22,843.64 Intangible assets Good will 665,000.00 Other assets Setting-up costs $ 1,101.14 Deposit on purchase of a sign 2,000.00 Improvements to leased premises— at cost less accumulated depreciation 3,753.29 6,854.43 $875.728.85 Liabilities Current liabilities Accounts and expenses payable $ 24,373.91 Federal and provincial income taxes 125,676.04 Other taxes and charges 934.23 150,984.18 600,000.00 Owed to directors Shareholders’ Equity Capital stock Authorized: 50,000 no-par ordinary shares Issued and paid up: 200 ordinary shares $ 2,000.00 Undistributed profits 122,744.67 124,744.67 For the board of directors $875,728.85 For the purposes of this appeal and in order to arrive at a fair valuation of the assets in question, it should be noted that the principal source of the income of Services Farmico Inc consisted of royalties paid by pharmacies which, through a franchise, obtained the right to use the trade name “Pharmacies Jean Coutu Enrg” or “Pharmacies Escompte Jean Coutu”. ... These would include, inter alia: —Use of trade name; —counsel, advice and assistance relating to the organization of, and planning for, the pharmacies; — possibility of purchasing from franchisor; — publicity, advertising and promotion; — initial assistance and guidance during start-up period. ... The financial statement prepared by Mr Wise reads as follows: SCHEDULE II SERVICES FARMICO INC VALUATION OF INTANGIBLE ASSET (RIGHT TO RECEIVE INCOME UNDER CONTRACTS) Results of 4 operating pharmacies Franchisable Pharmacies Total sales Franchisable Net Net 31/5/70 1 $1,302,519 $ 241,065 $1,061,454 31/5/71 1 Yr /smos 2,748,846 357,027 2,391,819 31/5/72 3 5,053,179 1,013,493 3,039,686 31/5/73 3 Yrs 1/9 mos 8,524,211 1,710,345 6,813,866 Sales for 4 pharmacies on 1973 basis each $1,817,031 @ 4% (4 pharmacies) 290,725 Advertising (See page 9) $125,000 Other expenses (See page 10) 100,000 225,000 Pre tax income 65,725 Tax 48% 31,548 After tax income $ 34,177 Multiple 3% 4 /2 Range (rounded) $119,600 $ 153,800 Having already concluded that the intangible assets acquired by Services Farmico Inc on June 26, 1973 constituted eligible capital property, I accept Mr Wise’s valuation, and I find that the market value of these assets on the date of their acquisition was $150,000; this also fixes the amount of the eligible capital expense which the appellant incurred to acquire these assets at this moment. the appeal is accordingly allowed in part and the matter referred back to the respondent for re-assessment, taking into consideration that the amount of the eligible capital expense is $150,000, and that paragraphs 14(5)(b) and 20(1)(b) of the Income Tax Act, SC 1970-71-72, c 63, as amended, must be applied. ...

Also the American parent company, Webb & Knapp Inc of New York, was in trouble, which reflected seriously on the credit of the Canadian company. ... In the administration of their affairs, Webb & Knapp (Canada) Ltd treated all real estate holdings as inventory, and all sales of buildings and real estate were reported as income items. ... Firstly, it acted as a conduit pipe for the levelling of profits, and second, it functioned as a manager under an arrangement with its parent company, Webb & Knapp (Canada) Ltd. ...

On Septemer 21, 1972 by agreement with other investors, Merban acquired an option to purchase 375,000 shares of Kaps Transport Limited @ $10 per share, (Exhibit A-8) 2. ... I would recommend that our participation be structured as a term loan for 3 years of $2.5 million (equal to $5.56/Kaps share) at Prime + /2 % and a $1 million 6V2 % preferred share investment put up by TD Capital Group. ... (c) The common shares in MKH were to be issued for a total consideration of $1,250,000 as follows: Merban $1,021,500 Reinhold Kapchinsky $ 125,500 Casamont Limited 112,500 7. ...