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While that’s not a great indication, his wife’s conduct in coming back to Canada is certainly not very great support for the appellant’s contention that the spatial bounds of their “lives” — in the plural — had been relocated to Ireland. (9) He returned to Canada for all family funerals. ... Ultimately, therefore, we come down to one point — his own testimony is that during the period 1976, 1977 and 1978 up until about August, he was employed by a company, TARA, and not by Canadian Mine Services. The possibility — and I emphasize that word — is that he was employed in the years 1976, 1977 and 1978 by TARA, allegedly an Irish company, and not by Canadian Mine Services. ...

The only witness called by the appellant was Paul J Martin, chief appraiser of John R Marsh & Co Limited, a firm of hotel brokers and appraisers. ... CHARACTERISTICS AND COMPONENT CAUSES OF GOODWILL IN BEVERAGE TAVERNS General Facts — Licence The licence is the primary or root cause in the development of goodwill. ... One of the witnesses called by the Minister was Mitchell A Smith, CA, of the firm of Laventhol & Horwath, management consultants. ...

Mr Pike was under the impression that merely showing that a profit could be made from an operation in some year — (in fact that a profit was possible) — legitimitized all prior expenditures of the operation as deductible against other income in the years in which they were incurred. ... In my mind that general proposition — the alleged immediate deductibility of operation losses from other income — is the genesis of the difficulty encountered by this taxpayer. ... Sustained losses for a period of five years or more — even if a portion of that time is admitted to have been as a hobby — could also militate against the appellant. ...

Of the $40,000 purchase price, the purchasers’ solicitors paid $36,000 to Pacific and, at the request of the appellant Andrew Tulloch, on February 20, 1964, issued a cheque for the balance of $4,000 to the Main & Hastings Branch of The Royal Bank of Canada in Vancouver, which amount was deposited in the Manager’s Account at that bank. ... Being eager to complete the transaction and put the “Sea Prince” into service with as little delay as possible, Blaine Myers & Co Ltd somewhat reluctantly issued their cheque for $3,000 to the appellant personally on February 25, 1964. ... It should be noted here that, although Crescent was the party that had agreed to purchase the “Sea Prince” under the agreement of February 19, 1964, none of the transactions whereby the “Sea Prince” was eventually transferred or sold to Blaine Myers & Co Ltd was recorded in the books or financial records of Crescent. ...

The appellant’s function was “... to direct television commercials and also to help to get that business in”. ... (SN page 59) (e) Mr Brandes “... had a good reputation as a director and had been in business for himself. ... Cases at Law — Analysis 4.01 Cases at Law Counsel for both parties referred the Board to the following cases: 1. ...

The amount deductible in computing taxable income under the provisions of subsection 110.1(1) (as it reads in its application to the 1975 taxation year) is expressed as “... ... Exhibit A-2, the trade slip from N L Sandler & Co, shows that the bonds allegedly purchased were purchased from the broker as principals. 3. ... At no time did N L Sandler & Co Ltd ever become obliged to pay the said sum to the appellant. ...

Suffice it to be said that the testimony and evidence support only one conclusion — that the Liquor Board employees knew they would be getting their “net pay” cheques while on strike — when they agreed to go on strike and that, without that understanding, they would not have gone on strike. ... That does not dipose of the second arrow in the Minister’s bow — that the amount is “income... from a source”. ... The Board then turns to the real question in this appeal — the taxability of strike pay. ...

. — In 1965 the appellant successfully made application to the Town of Burlington (as it then was) to rezone the property from “RA3” to “RM3” in preparation for its anticipated building on the property. — In 1966 the appellant submitted detailed construction drawings to the Town of Burlington for a multiple unit residential complex tentatively named “Glendor Court”. — From 1966 to 1971 the appellant approached many lenders with a view to seeking financing for the building of Glendor Court as a multiple unit residential rental complex. The appellant was unable to interest any lender in its development plan for the property. — In 1969, a small part of the property was sold to the Hydro-Electric Power Commission of Ontario which required same. The proceeds of disposition were treated as a receipt on account of capital and deducted from the book value of the land as carried on the books of the Corporation. — In 1972 one of the principals of the appellant became ill and was no longer able nor willing to continue promoting the development of the property. ...

Mr Fernand Fournier Salary Total (Hilton Tips Tips Tips Tips tips 163(2) Hotel) reported added assessed penalty 1976 — 6,367.95 nil 11,749.00 11,749.00 423.17 1977 — 6,246.50 nil 11,749.00 11,749.00 407.87 2. Mr Carl Corbeil Salary Total (Hilton Tips Tips Tips Tips tips 163(2) Hotel) reported added assessed penalty 1976 — 5,697.91 300.00 7,105.00 7,405.00 282.62 1977 — 5,880.20 450.00 6,955.00 7,405.00 286.10 3. Mr Jean-Paul Sarradet Salary Total Total (Hilton Tips Tips Tips Tips tips tips 163(2) 2) Hotel) reported added assessed penalty 1976 — 7,164.05 nil 6,524.13 6,524.13 275.82 1977 — 5,848.36 500.00 6,024.13 6,524.13 241.50 4. ...

Lake have “in writing” stated separate & living apart at a different address and 7 corresponding files from J.B. ... Regards (Sgd) Quentin Feb. 28/75 Quentin — The arrangement on the payments will be O.K. — to total $10,000 for the year. ... Jean Formerly (510 + 320) but since two rent increases it is better for me to go (530 + 300) So last cheque was 300- 30.00 = $270.00 (ski boots) Are you still paying Terry an income? ...