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The appellant’s shareholder’s loan account showed the following balances at the fiscal year end of Eddie Sargent Promotions Ltd viz, June 30, and at the calendar year end, for the years 1974 through 1979; Year June 30 December 31 1974 $ 49,287.00 $ 75,162.00 1975 87,860.00 109,380.00 1976 135,745.00 154,796.00 1977 83,533.00 113,049.00 1978 93,369.00 109,671.00 1979 88,785.00 7. ... See also: The Queen v Ogilvie (1898), 29 SCR 299: Thomson v Stikeman (1913), 29 OLR 146; affirmed 30 OLR 123 (CA); A R Williams Machinery Company Ltd v Moore & Murphy, [1926] S.C.R. 692; Paradis & Sons, Limited v Silesse, 1931,3 MPR 565 (NB); Netting v Hubley (1894), 26 NSR 497 (CA). ... The appellant relies completely on the Clayton Rule — namely, the allocation by the debtor as to which loan repayments are made to his creditors, in this case Eddie Sargent Promotions Ltd. ...

So, I went back to Ken Aitken — Q. By telephone or — A. By telephone. And I told him this and he came back — Q. Can I just — you say, “I told him this”. ... It was in — it was beyond November, probably about the middle of November. ...

Q To determine that, did you examine any documentation from N L Sandler & Co? ... Argument The position of the agent for the appellant came down to: —“... ... The argument of counsel for the respondent may be summarized as follows: —... ...

The total amount, in other words the full $73,000, was not payable by Redco to Norbraten until two months of consecutive default — in effect, once the account was rendered. ... Whether that calculation is proper, the Board need not determine under the circumstances of this case — that is not the point to be considered at this time. ... The point in this appeal is not whether the amount must be included in the appellant’s income — that is mandatory — but whether if, after such inclusion, a reserve is proper. ...

Exhibit A-4 — Same as above, dated April 22, 1974 signed by the appellant. Exhibit A-5 — Bank Statement—August 1974. Exhibit A-6 &) Cancelled cheques signed by the appellant to Helen Hollo A-7) (the appellant’s mother). ... Exhibit R-3 — Union Gas Limited account for $6.39—October 1974. Exhibit R-4 — Same as above for $1.02—September 1974. ...

. • During the relevant years together with Mr Beghin, Mr Wyrzykowski sought to acquire and did acquire some lands in and around the town of Lorette, Province of Manitoba. ... In each case the farm land acquired and subsequently sold (Glass, Sarrasin and Rosewood specifically) was exactly that — serviceable and operative for the purpose of farming. ... The sole motive (certainly the prima facie purpose) at acquisition was for the purpose outlined by the appellants — investments for immediate farming. ...

. — an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; Property is defined in subsection 248(1) of the Act as: “Property” — “property” means property of any kind whatever whether real or personal or corporeal or incorporeal and, without restricting the generality of the foregoing, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, and (c) a timber resource property. ... The legal fees paid by the taxpayer to have that right confirmed by the courts and recognized by the trustee did not create the right — it merely enforced it upon the trustee. ... Evans’ legal right to the / share income existed prior to the payment of legal fees; the expense was incurred so as to receive the income to which she was already entitled. ...

Contentions The appellant asserted: — I was divorced in 1972 in UK and under the terms of the divorce, I was obliged to pay a small weekly maintenance payment for each of my three children and school fees for the two oldest. This was in lieu of alimony. — In 1974 and 1975 Canada Revenue Taxation allowed me to use the school fees and maintenance payments as tax deductions but in 1976 changed their minds when I inquired about claiming for 1973. — I have paid every cent under the divorce agreements. ... —The appellant’s allegations with respect to his 1974,1975 and 1976 taxation years are admitted but they do not determine the issue. — In his returns for those years, the appellant claimed the deductions from income set out below: 1974 Maintenance $1,382.00 School fees 3,923.65 $5,305.65 1975 Maintenance $1,382.00 School fees 5,118.00 $6,500.00 1976 Maintenance $ 839.80 School fees 4,075.50 $4,915.30 —The assessment for 1974 disallowed the deduction of school fees claimed allowing only maintenance payments required under the Court Order of May 8, 1972 in the amount of $1,382. ...

Gross Expenses and Net Sales Profits Depreciation Income 1973 $186,016.81 $12,259.33 $ 7,358.87 $ 4,900.46 1974 299,856.87 30,285.03 9,719.81 20,565.22 1975 373,960.03 32,428.64 14,438.58 17,990.06 3.05 Mrs Marie Fernande Lahaie, the appellant’s wife, testified that she was a pump attendant and secretary and kept the books. ... These figures were taken from the balance sheet prepared by the respondent’s accountant and admitted by the appellant’s accountant. 3.10 During 1977 the respondent’s auditors, as the result of a net worth audit, established the following additional income: 1973: $12,166.23 1974: $17,043.61 1975: $ 7,830.27 3.11 These additional amounts of income were admitted by the appellant. 3.12 Evidence was further presented that, during the years in question the appellant purchased bank certificates and reduced mortgages in the following amounts: Reduced Certificates Mortgages 1973 $ 2,100 $ 7,000 1974 13,000 12,000 1975 Nil 6,000 4. ...

In the said reassessment the Minister of National Revenue made the following adjustments to declared income: Net income as reported $ 4,26 Add: (1) Interest expense not allowable 76,344.31 (2) Professional fees not allowable 2,460.00 Revised taxable income $78'808'57 Upon Notice of Objection duly signed and filed the Minister confirmed the assessment on the ground (a) that bank interest of $76,344.31 was not interest on borrowed money used for the purpose of earning income, and (b) that professional fees of $2,460 claimed as a deduction from income were not incurred in the course of borrowing money used for the purpose of earning income. The appellant’s profit and loss statement for the year ended June 30, 1963, which includes only seven months of operations, contained in summary and amended form the following: Income (mainly rents) $240,883.08 Expenses (mainly general, office and administrative) $155,006.02 Professional fees re: borrowed money expenses 2,460.00 157,466.02 Operating Profit 83,417.06 Interest expense: To Bank of Montreal $ 20,422.34 To Great West Life 55,921.97 To Shareholders’ loans being 6% on $200,000 July 1/62 — Jan. 31/63 (215 days) 7,068.49 83,412.80 Profit before taxes 4.26 Provision for income taxes.89 Profit for year $3.37 The appellant company owned and operated an office building in Vancouver and, during June 1962, became engaged in a series of financial transactions, pursuant to which it assumed certain legal obligations to pay interest to money-lenders. ... These loans and advances were reflected on the appellant company’s current bank account with the Bank of Montreal as follows: June 27, 1962 — Opening Balance Nil Deposit by shareholders $ 200,000.00 Deposit (loan Bank of Montreal) 500,000.00 Deposit 1,500,000.00 TOTAL $2,200.000.00 These borrowings were to pay off certain existing indebtedness and thereby make fully available certain unencumbered assets as security for the new loans. ...