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The amounts for the years in question are as follows: (a) in the case of Placements LTG Inc: 1973 $15,000; 1974 $41,000; 1975 $ 8,000 and again in 1975 $ 6,500, of which operating profits were $ 6,500, which was also reported. (b) in the case of Placements EQ Inc: 1972 $15,000; 1973 $16,000; 1974 $19,000; 1975 $ 9,000. ...

Interest and Bank charges: $10,707 Travel and Entertainment: $ 2,274 Depreciation Expense: $17,922 The net income, before tax, was used in the application of the rate of return. 3.11 The respondent’s appraiser, Mr Koivane Yuh, computed the value of the farm on the basis of seven sales, not of cranberry lands, but on blueberry lands, shallow peat lands, and bared lands acquired in 1971 and 1972. ... It was his mandate — the business portion being calculated by another appraiser. 3.12 Another appraisal report (Exhibit A-7) was made by Mr E W Palmer of Bell-Irving Realty Limited in February 1969. ... Therefore, the best way to establish the value of the farm is the income approach, unless it could be proved that the liquidation value or the real estate value were higher. 4.02 The points in dispute between the two appraisals made pursuant to the income approach method are first, the amount of $30,903 of expenses (interest and bank charges — $10,707; travel and entertainment — $2,274; depreciation expense — $17,922) which, according to Mr Anderson, are not directly attributable to the real estate operation of the subject, and secondly, the amount of $40,000 computed under the 1972 Income Tax Act. 4.03 The Board does not see why interest and bank charges would not be taken into account, even if it could be said that this expense is “not directly attributable to the real estate operation of the subject”, ie, of a cranberry farm. ...

One such plan, in which the appellant had in prior years deposited $2,000 and had in the interim augmented to $2,113.50, was referred to by the Company as the “B & M fund”. In November 1974 the appellant instructed the Company to transfer from his B & M plan the amount of $2,113.50 and open a similar plan for him in its "guaranteed fund”. ... Counsel for the respondent argued that the law was clear and that the proceeds of the termination of the B & M fund must be included in income. ...

For 1975 the respondent decreased reported income from the appellant’s office as president of a company called A & B Rail Contractors Ltd (hereinafter called “A & B” or “the Company”). ... At all relevant times the appellant was president and holder of 51 % of the issued shares of A & B. ... The bookkeeping was explained by Donald Stuart Fraser, the accountant for the appellant and A & B. ...

Mr Overdyk submitted that his office chair was a wheelchair — it certainly fitted the dictionary descriptions as he read them — (a chair equipped with wheels). ... Counsel noted the reference in subparagraph 110(1)(e)(ii) of the Act to “remuneration for an attendant”, and that a separate section of the Act — 110(1)(c)(ix) — made provision for certain deductions for a “brace for a limb”. ... That is not the situation before the Board in this matter — this taxpayer has no such option — his illness is totally disabling unless he has external assistance of some kind. ...

There is no dispute as to the following facts: — The property is situate in Ontario. — In 1964 David and Diane Opie sold the property to Emerald Isle Motel Limited (“Emerald Isle”). — In 1965 Emerald Isle mortgaged the property to Crédit Foncier Franco- Canadien (“Crédit Foncier”) in the amount of $132,000. ... (This is the mortgage in question.) — In July 1970 Emerald Isle sold the said property to Black Prince Holdings Limited (“Black Prince”). ... The Court was not using a provincial statute to define a word in a federal Act, but rather was determining what the business was — a proprietorship or a partnership — and once deciding that, applied the federal law. ...

The said application for an extension contains the following facts which, in my view, summarize the problem: — On March 5, 1979 the respondent assessed the applicant for the 1976 taxation year in the notice of assessment bearing No 410802; — On May 31, 1979, the applicant filed a notice of objection against the above- mentioned notice of assessment; — On August 19, 1980 the respondent issued by registered mail a Notification of Confirmation by the Minister relating to the above-mentioned notice of assessment; — The applicant did not learn of the sending of this Notification of Confirmation by the Minister until early October 1981; — Since she did not know of the sending of the said Notification of Confirmation by the Minister until early October 1981, the applicant could not institute an appeal to the Court within the prescribed time, namely, within ninety days from the date of mailing of the said Notification; — The Notification of Confirmation by the Minister was not sent to the applicant personally but rather to her accountant with a copy to her lawyer; — The applicant has lived in France since early 1979. ... Counsel for the applicant filed the following documents: — A letter dated July 7, 1980 from Revenue Canada to the applicant addressed to “Côte St Catherine Road”, which related directly to the notice of objection involved in this application; — A receipt from Revenue Canada dated July 15,1980 sent to the applicant at the address on Henri Bourassa in part payment of the tax payable. ... The tax form she used was the current form with the previous address preprinted thereon and sent to her by Revenue Canada. † The change of address from Côte des Neiges to Henri Bourassa did not appear on the forms sent by Revenue Canada for 1978 and 1979. ...

Since the incorporation of Velan Engineering Ltd the appellant has been the sole owner of its legal capital which was as follows: (a) Common shares of $100 par value, authorized, issued and fully paid 250 shares (b) Preferred shares, 5% non-cumulative, par value of $100 — authorized 2,750 shares — issued and paid 1,530 shares On December 31, 1964, the appellant sold to Canadian Aviation Electronics Ltd (hereinafter referred to as “CAE”) 50% of all his shares, that is to say, 125 common shares and 765 preferred shares, for an amount of $750,000. ... Total price $770,400.00 Less: Value of preferred shares $100 x 765 shares 76,500.00 Price for 137,500 common shares $693,900.00 Price per common share $ 5.04 In 1968 the appellant made another gift of common shares of Velan Engineering Ltd — this time to his three sons, Ivan, Peter and Thomas — and declared the value of these shares to be $5.90 each. ... The appellant, who pleaded his own case, did his utmost to show that the shares given to his son Peter had a value of only $2.80 per share and even went so far as to introduce new evidence in his written argument — which procedure, of course, is not permissible because the new alleged facts have not been proven. ...

The misrepresentations consisted in the appellant reporting and omitting the following income: Reported Omitted 1967 $3,170.00 $30,000.00 1968 2,204.00 11,000.00 1969 102.24 17,000.00 1970 730.40 4,000.00 1971 1,963.00 8,000.00 5,953.00 1,000.00 1972 (loss — 338.00) 2,818.00 In addition, in 1975 the appellant pleaded guilty to having defrauded the National Revenue Department. ... The said service stations had been purchased as follows: 1962 — St-Jean service station 1963 — Iberville service station 1964 and 1965 — Châteauguay and Varenne service stations He also advised Mr Durocher to incorporate the appellant company in 1966, so that it could become the owner of the new service stations he would be purchasing. ... Counsel then referred the Board to the following decision to show, first, that the intent to sell at a profit must exist at the time the assets were purchased, and also that secondary intent is insufficient to make a transaction commercial in nature: MNR v Foreign Power Securities Corp Ltd, [1967] CTC 116; 67 DTC 5084; Birmount Holdings Ltd v The Queen, [1977] CTC 34; 78 DTC 6254; Racine Demers & Nolin v MNR, [1965] CTC 150; 65 DTC 5098; Choice Realty Corp v The Queen, [1978] CTC 613; 78 DTC 6415. ...

In his income tax return, the appellant stated he had been separated from his wife for 38 weeks and had had hired help for 19 weeks. 3.05 During the years in question, the following expenses were claimed by the appellant and disallowed in whole or in part by the respondent as indicated: 1976 1977 1977 1978 1978 Legal expenses claimed nil $ 805.00 $ 500.00 allowed nil nil Child care expenses claimed $3,274.77 $2,355.91 $3,422.07 allowed nil $ 570.00 $1,000.00 4. ... In the present case, as there is only one child, the final product is therefore $840 (28 * 30 * 1). The respondent, in computing the exemption, took only 19 weeks into account, or the number for which the appellant stated he had hired help (para 3.04), and thus allowed only $570 (19 * 30 * 1). ...