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He cited [supra] Front & Simcoe Limited v MNR; No 665 v MNR, Dewar v MNR; Her Majesty the Queen v Cadboro Bay Holdings Ltd; No 682 v MNR. ... Those special circumstances can be that the amount paid for the franchise is only a diminution of the price of the rent as in the case of Front & Simcoe Limited cited above. ... In the present case, the price of the rent is 11 % of gross sales, (paragraph 3.13 of the Facts) in fact more than the general rule. ...

Mr Koch proceeded to obtain a rental property available through the British Government in Slough in England and formed an English company in which he held 50% of the stock and his English representative — I believe his name was Wiseman — held the other 50%. ... These, briefly — or perhaps not too briefly — are the facts as they have unfolded during the course of the hearing. ... What then did he do — what was there in his actions — to convince me that this was really his intention? ...

The law of contract imposes an obligation on each of the contracting parties to a legally enforceable contract — here it was the agreement between the Bohun Brothers and Reynolds — to keep faith with one another and there is no reason whatsoever, in my view, why that agreement should not be interpreted and enforced precisely in accordance with its terms. ... In precipitating the present confrontation with the Minister — which is precisely what the three appeals herein add up to — Reynolds has committed a serious breach of its agreement (contract) dated July 13, 1965 with Peter Bohun and Dick Bohun which has most unfortunately involved them in unnecessary expenses in sticking up for their rights under the said agreement. 5. ... Paragraph 20(6)(g) is a rule — quoting from page 20-610 of the Canada Tax Service — “designed to cover the situation where a lump sum consideration is received in respect of the disposition of depreciable property of a prescribed class and for other assets such as depreciable property of some other class, or for goodwill or land.... ...

The agreement also gave the purchaser the right to use the firm name George Loos & Co. ... In fact, the appellant had his office in the same building as A H Roy & Associates. ... The assets of A H Roy & Associates could not be taken into consideration in evaluating the goodwill. ...

Unreported interest of $14,083 remained ($83,372- $69,289 ($24,880 + $44,409) = $14,083) (Exhibit 1-1). ... Law — Cases At Law — Analysis 4.01 Law The provision of the Income Tax Act involved in the instant case is subsection 163(2). ... Dona Legros & Barbara M Legros v MNR, [1981] CTC 2142; 81 DTC 99; 3. ...

In the period from August 1, 1972, to March 31, 1979, the Appellant bought, operated and sold the following hotels in the Province of Alberta: (a) Alberta Beach Hotel Purchased August/72 $ 243,249 Sold in 1973/74 fiscal year 267,876 Capital gain reported on 1974 return 23,401 (b) Royal Hotel Ponoka Purchased February 1/74 $ 585,193 Sold April 1975 660,000 Capital gain reported on 1976 return 45,407 (c) Innisfail Hotel Purchased September/75 $ 500,000 Sold January 1976 580,000 Capital gain reported on 1977 return 12,800 (d) Lethbridge Hotel Purchased November/76 $ 975,000 Sold November 1977 1,100,000 Capital gain reported on 1978 return 108,162 (e) Stettler Hotel Purchased March/78 $ 711,000 Sold February 1979 837,000 Capital gain 26,000 The appellant’s agent, Henry Reich, was engaged in a family trucking business for a number of years and was a shareholder, but mainly acted as a “grease monkey” and sometimes drove a bus. ... Mr Reich was advised by an hotel sales expert of City Savings & Trust to invest his funds in the purchase of the Royal Hotel at Ponoka, Alberta, which he did on February 1, 1974. ...

Here are the names of the companies with the value of the shares and the amounts of the loans: Value of Shares Loans Ste-Dorothée Dev Corp $37,918.00 $ 1,276.00 Key Acceptance Corp 14,212.00 2,862.00 Guard Development Corp 5,456.00 2,066.06 Manhattan Development Corp 11,900.00 18,612.44 Wentworth Development Corp 27,600.00 39,548.64 Fides Development — 1,773.34 Civic Land Development Corp 13,414.00 2,933.36 Twin Development Corp 20,126.00 60.00 Wentworth Corp 10,012.00 Newtrend Dev Corp 17,980.00 Colony Dev Corp 50,046.00 Forward Dev Corp 7,864.00 Broadway Construction Co 73,250.00 Ultra Development Corp 9,552.00 Wentworth Dev (Ont) Ltd 1,001.00 Metra Investment Ltd 3,850.00 Salada Foods Ltd (Ont) 150.00 TOTAL $304,331.00 69,132.50 As to the first liability of $84,628, the following documents were filed: (1) Exhibit A-6 — A document dated May 7, 1954 and signed by Louis Zbarsky and Louis and Sam Landsman showing that they were jointly and severally responsible for the said debt of $253,888.73 to the Bank of Montreal. (2) Exhibit A-7 — Judgment No 796524 of the Quebec Superior Court dated June 7, 1971, showing that Louis Zbarsky, Louis Landsman and the late Sam Landsman had to pay the sum of $253,888.73. As the second liability of $51,605.89, the following documents were filed: (1) Exhibit A-3 — Judgment No 759186 by Mr Justice Challies. (2) Exhibit A-8 — Confirmation by the Bank of Montreal to the effect that the Estate was indebted to the Bank for the amount of $51,605.89 as of Feb 2, 1968. ...

Benrush Holdings Limited was the controlling shareholder of John Northway & Son Limited, a public corporation which carried on another department store business known as “Northway” in competition with the Appellant. 4. ... The aforementioned loan agreement provided that the term of the loan was six months from October 25, 1961 to April 25, 1962, the rate of interest was 12% per annum, and Benrush Holdings Limited hypothecated and pledged 880,000 common shares in the capital stock of John Northway & Sons Limited as security for the repayment of the loan. 8. ... The first agreement reads as follows: MEMORANDUM OF AGREEMENT made this 25th day of October 1961, BETWEEN: BENRUSH HOLDINGS LIMITED, a company incorporated under the laws of the Province of Ontario, having its head Office in the City of Toronto, Hereinafter called “Benrush” OF THE FIRST PART: — and — THE MAY COMPANY LIMITED, a Company incorporated under the laws of the Province of Ontario, having its head office in the City of Toronto, Hereinafter called “May Company” OF THE SECOND PART: — and — DAVID RUSH, of the City of Toronto, in the County of York, Executive, Hereinafter called “Guarantor” OF THE THIRD PART: WHEREAS May Company has agreed to lend to Benrush, the sum of Three Hundred and Twenty-Five Thousand ($325,000.00) Dollars on the terms and conditions hereinafter set out and Benrush has agreed to hypothecate and pledge Eight Hundred and Eighty Thousand (880,000) common shares of the capital stock of John Northway and Son, Limited as security for repayment of such loan; AND WHEREAS Six Hundred and Six Thousand, Nine Hundred (606,900) common shares of capital stock of John Northway and Son, Limited are Subject to escrow, and are to be released as to one-third (Zj) on the 30th day of November, 1961, as to one-third (Va) on the 28th day of February, 1962, and as to the balance on the 31st day of May, 1962, subject as to all or part to earlier release with the written consent of the Ontario Securities Commission. ...

To conclude, acceptance can be implied from the following circumstances, among others: — the fact that the former spouse has been in possession of the document which is the subject-matter of the litigation; — the fact that the appellant drew cheques in accordance with the document and his former wife accepted them; — the fact that the former wife attested in writing that she had received these cheques as support allowance and that she even declared them as income for the taxation years concerned; — the fact that, when it comes to determining the amount of the support, a sum is provided to cover income tax so that the ex-spouse can receive a net amount; — the existence of an affidavit by the appellant, and so on. ... (b) The common law In common law legal theorists and case law recognize that a simple contract, as contrasted with a contract under seal, may be written; also that: — where the law does require that the contract be in writing this is to make it capable of proof; — signature by both parties is not necessary provided that the party to be charged has signed the document; — a written offer from one of the parties binds him once it is accepted orally by the other; — a signature by means of initials is sufficient. ... A perusal of the document makes it quite clear that it is a written separation agreement, for it covers all the effects of the separation, as follows: — the dissolution of the matrimonial regime; — the right of occupation of the appellant’s house by the former spouse and the children of the marriage; — the amount of the support allowance, broken down into its constituent sums; — custody of the children, visiting rights and rights of access; — the gift of an automobile, and so on. 4. ...

. ~- Appeal allowed in part. ...