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. — Desjardins began performance of the subcontract in early February 1976, with 20 and 25 employees. ... The amounts of all such cheques were stipulated to the taxpayer by Desjardins’ accountants Guimond Faucher & Cie, who at all relevant times acted solely for Desjardins to the exclusion of the taxpayer. ... In reviewing that question, the significant evidence as I see it is: — “R” made out cheques to the employees, and included thereon the name of “D”. ...

Mortgage Mr Mullins Discounts and guarantees, 4 mortgages Lending — Bill Mullens, Unity Bank, Kingsway, Bay & Gerrard, East Toronto. ... I have — I would say that I look at a minimum, sometimes it is like, it is one day, or a half a day investment of time. ... Victor V & Mary Spencer v MNR, [1978] CTC 2109; 78 DTC 1129; 6. HMQ v Samuel Eidinger, [1979] CTC 296; 79 DTC 5218. ...

In its 1967 taxation year, the Minister reversed the position taken by his officials in the earlier taxation years from 1959 to 1966 — as he clearly had the right to do — and assessed the appellant on the basis that it is not in the business of farming within the meaning of paragraph 139(1)(p) of the Act and, therefore, is not entitled to report its income in accordance with the provisions of subsection 85F(1) of the Act. ... In that connection, on the basis of the evidence before me in this matter, there should be a finding — and I so find — that the taxpayer was not at any relevant time in the business of preparing and selling books. ... It measures 10% inches by 8% inches and is only about ¥% of an inch thick when tightly compressed. ...

Mr Myles S Robinson, the appellant’s principal shareholder, had at that time been advised by the accounting firm of Ernst & Ernst that there would be advantages in making the appellant — whose operations were planned to extend beyond Winnipeg to other Canadian cities and to the United States — a public company. ... However, the only pertinence that these factors may have in the determination by the Courts of profit for tax purposes — once the legal requirements have been met — is the necessity of scrutinizing even more carefully which of a variety of GAAP are being invoked — as they are in this appeal — as an acceptable basis for the computation of income for tax purposes. ... For example, he is entitled to set up reserves — either expressly or implicitly — against unrealized losses. ...

Revenue Canada — Taxation granted the permission in a letter dated June 18, 1976, filed as Exhibit R-3. ... (SN page 53, Q 153) (m) The appellant company had another job in Indian Bay “... that wasn’t doin’ us any favours.. ... Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act involved in the present case are paragraphs 18(1)(e) and 78(3)(a). ...

The difference in the fair market value of the properties as of December 31,1971, as estimated by Mr Ford and Mr Corman is very substantial as can be seen by the figures contained in Exhibit A-11 and Exhibit A-23, which read as follows: (Exhibit A-11) D K CAMPBELL ANALYSIS OF LOTS 8 &9 SOUTH CAYUGA V-DAY VALUE 1975 ADJUSTED COST BASE Tax Ford- Ford- Tax Ford- Dept Corman Campbell Dept Corman Campbell Land—239 acres 505,500.00 Barn 102,570.00 4,500.00 102,570.00 505,500.00 Gas Shed 200.00 (1,300.00) Implement Shed 3,170.00 1,300.00 3,170,00 1,870.00 105,740.00 117,400.00 511,500.00 105,740.00 117,400.00 508,670.00 House 1 acre 17,430.00 19,600.00 47,500.00 29,300.00 26,500.00 100,000.00 123,170.00 137,000.00 559,000.000 135,040.00 143,900.00 608,670.00 Selling Price Farm 619,237.30 622,037.30 548,537.30 House & Acre 29,300.00 26,500.00 100,000.00 648,537,30 648,537.30 648,537.30 (3,170.00)* Farm Capital Gain 513,497.30 504,637.30 43,037.30 Less Outlays & Expenses 6,810.35 6,810.35 6,810.35 (3,170.00)* Capital Gain for Tax Purposes 506,686.95 497,826.95 36,226.95 (1,585.00)* Taxable Capital Gain—50% 235,343,47 248,913.47 18,113.47 16,528.48 Omitted from ACB in error in filing original return but reflected in ACB on Notice of Objection to give revised taxable capital gain of $16,528.48 instead of $18,113.47. (Exhibit A-23) S M SMITH ANALYSIS OF LOTS 15 & 16, Cone 7, S Cayuga V-DAY VALUE 1975 ADJUSTED COST BASE Tax Tax Tax Dept Corman Ford Dept Corman Ford Land $51,700 $55,700 221,760 173 Ac 1,300 $51,700 $57,000 $221,760 51,700 $ 57,000 $221,760 Sale Price $280,000 $280,000 $280,000 Less adjusted cost base 51,700 57,000 221,760 Farm Capital Gain $228,300 $223,000 $ 58,240 Less outlays & expenses 2,508 2,508 2,508 Capital Gain for Tax Purposes $225,792 $220,492 $ 55,732 Taxable Capital Gain-50% $112,896 $110,246 $ 27,866 Counsel for the appellants suggested that the Board should reject both appraisals and arrive at a V-day value of the properties on the basis of the information placed before it. ...

You remained a resident of Canada you stated, you retained ownership of your present home, you retained your membership in the Calgary Winter Club, and your salary was paid during 1978 by the Calgary Board of Education, with whom you were employed, and being an employee — and I might add a servant of the Calgary Board of Education — it was their responsibility to pay you. ...

However, to simply grant such extensions and imply that all applications — where the breach is but a few days — will be granted, is to make a mockery of the period of limitations set down in the Act. ...

(a) On the 31st day of December, 1978 — $4,000 (b) On the 31st day of December, 1979 — 4,000 (c) On the 31st day of March, 1980 — 4,000 16. ... (a) the facts hereinbefore admitted; (b) during the 1973 taxation year, the Appellant received the amount of $10,400 as a loan from Bathe & McLellan Construction Limited for the purchase of 200 of the issued and outstanding common shares of HVS Steel Products Limited (“HVS”); (c) during the 1974 taxation year, the Appellant received the amount of $18,000 as a loan from Simcoe Rentals Limited for the purchase of 300 of the issued and outstanding common shares of HVS; (d) during the 1975 taxation year, the Appellant received the amount of $28,000 as a loan from HVS to enable him to repay his outstanding loans to Bathe & McLellan Construction Limited and Simcoe Rentals Limited; (e) by Resolution of the Board of Directors of HVS dated the 22nd day of June, 1978, HVS confirmed and ratified that it had made a loan of $28,000 to the Appellant, which loan was stated to be to enable the Appellant to purchase shares of HVS as of April 2, 1975, and which loan was stated to be repayable by equal annual instalments of $7,000 per annum without interest commencing as of the 2nd day of April, 1976; (f) no amounts had been paid by the Appellant on account of the loan made by HVS in its 1975 taxation year as at the end of its 1976 taxation year; (g) bona fide arrangements were not made at the time and the loan was made by HVS to the Appellant for repayment thereof within a reasonable time; Findings of facts: The evidence of the appellant and Mr McLellan can be briefly summarized as follows: The appellant and two other persons founded HVS Steel Products Limited in 1968. ... Simcoe’s deposit book (Exhibit A-1) shows a deposit of $18,900 on April 2, 1975, with a notation: “P Hendriks — $18,900 (Princ $18,000, Interest $900)”; Bathe’s deposit book (Exhibit A-2) reflects a deposit of $12,686 on April 2, 1975 with a notation: “P Hendriks — $12,686 (Princ $10,400, Interest $2,286)” which is in accord with a statement prepared on Bathe’s letterhead (Exhibit A-3). ...

Law — Cases at Law — Analysis 4.01 Law The main provisions of the Income Tax Act, SC 1970-71-72, Chapter 63 as amended, involved in the present case are 150(1)(a), 162(1), 186(1) as passed before the amendment of December 6, 1979, the amendment to subsection 186(1) found at subsections 56(1) and (2) of 28 Eliz Il, Chapter 5, and subsections 187(1), (2) and (3). ... Cable Mines <& Oils Limited v MNR, 28 Tax ABC 42; 61 DTC 641; 3. ... Is it correct to refuse to pay interest charged from March 31, 1979 (“... the last day of the third month after the end of the year...” subsection 186(1) introductory paragraph) by the respondent? ...