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At this juncture, it is interesting to reproduce the appellant’s Profit and Loss Statement which was filed with its return for the year ending July 31, 1959: H F POLLOCK AND CO (EAST ASIA) LTD PROFIT AND LOSS STATEMENT — (Canadian Dollar Account) FOR YEAR ENDED JULY 31, 1959: EXPENSES COMMISSIONS $281.07 Legal and Audit Fees $250.00 Interest and Bank charges $ 7.27 Taxes and Licences $ 51.11 NET LOSS ON OPERATIONS $589.45 H F POLLOCK AND CO (EAST ASIA) LTD TRADING AND PROFITS AND LOSS STATEMENT (Yen account converted at 360 Yen::; $1.00) FOR YEAR ENDED JULY 31, 1959: INCOME Nil EXPENSES Depreciation — furniture and fixtures $ 32.86 NET LOSS TRANSFERRED TO SURPLUS ACCOUNT $ 32.86 In the 1958 taxation year the appellant company’s receipts were $42,088.90 and the expenses $42,600.00, resulting in a small loss. ...

Counsel for the Minister has noted the wording of paragraph 109(1)(b) and I read it for the record: “Wholly dependent persons — In the case of an individual not entitled to a deduction under paragraph (a)”, and then the section goes on to provide essentially the same dollar deduction as that provided under paragraph 109(1)(a). ... Paragraph 109(1)(b) has therein the condition precedent that we have noted: “not entitled” and in the event that a taxpayer “is entitled” to a deduction under paragraph 109(1)(a), paragraph 109(1)(b) is not open to him — not only is it not open to him for deduction, it is not even activated as a potential deduction section. ...

The notice of objection was signed by me at the office of my authorized agent, Proulx, Boyer, Charbonneau & Associates, on September 6, 1979. 4. ... It would seem to me that the interpretation placed upon the circumstances by counsel for the Minister is more plausible — that the matter did not receive the attention it warranted (whether of the taxpayer or his advisers), and that no adequate explanation of the delay has been presented. ...

Facts 3.1 According to the respondent’s auditor, Mr Charles Raymond, an article appeared on January 7, 1975, in the newspaper “La Presse” (Exhibit 1-1) concerning certain accounts maintained under false names at the Bank Canadian National in Louiseville. 3.2 On January 24, 1975, the bank in question received from the respondent, through the Special Investigations Section, a requirement for information (Exhibit I-2) relating to individuals who might be connected with these accounts maintained under false names. 3.3 On February 24,1975, the respondent was provided with a reply (Exhibit I-3) which mentioned, among others, account No V-983 in the name of Mr Jos Paillé, whose real name was Reginald Paillé, the appellant. 3.4 On March 7,1975, the appellant made a voluntary disclosure admitting, among others, omissions from his returns for 1973 and 1974. 3.5 According to the auditor, a review of the bank account of the summary of deposits shows that all the deposits were made in cash. 3.6 The amounts added as a result of the voluntary disclosure to the income already reported by the appellant are as follows: Previous Amount Amount Added Total 1973 $62,748.69 $40,173.25 $102,921.69 1973 $53,732.92 $ 2,000.00 $ 55,732.92 3.7 The 25% penalties amounted to $3,069.87 for 1973 and $163.32 for 1974. 3.8 Following the issue of notices of assessment on February 27, 1976, notices of objection were filed on May 25, 1976. 3.9 Following the respondent’s notification of December 14, 1976, confirming the notices of assessment of February 27, 1976, an appeal was filed with the Tax Review Board on January 12, 1977 in relation to the penalty only. 4. ...

Counsel for the respondent submitted that the Contract for Part-Time Teaching was an employment contract, and that in addition to the Sim case (supra), the Board should consider the following: H Lionel Rosen v The Queen, [1976] CTC 462; 76 DTC 6274; Donald B MacDonald v MNR, [1974] CTC 2204; 74 DTC 1161; Dr W H Alexander v MNR, [1970] Ex CR 139; [1969] CTC 715; 70 DTC 6006; Market Investigations Ltd v Minister of Social Security, [1968] 3 All ER 732: Stevenson Jordan & Harrison Ltd v MacDonald and Evans, [1952] 1 TLR 101; Morren v Swinton & Pendlebury Borough Council, [1965] 2 All ER 349. ...

The appellant owned all the shares of William Scott & Company Limited of Vancouver, British Columbia and Centennial Hatcheries & Breeding Farms Limited of Hammond, British Columbia, which companies were involved in the poultry-raising business and were managed by the appellant, for which the appellant received a management fee. ...

The taxpayer, that is, the appellant, with another, incorporated a corporation known as Windermere Management Limited which in turn acquired shares in a corporation known as McCaffreys Hi Fi, TV & Appliances Limited and, as a condition of the purchase of McCaffreys’ shares, the taxpayer, that is, the appellant, was required to guarantee McCaffreys’ indebtedness to McCaffreys’ bank. ... & Appliances Limited (hereinafter referred to as “McCaffreys”); (c) the Appellant became guarantor of a loan in the amount of $2,000.00 made by the Toronto Dominion Bank to McCaffreys; (d) McCaffreys subsequently went bankrupt, and the said indebtedness to the Toronto Dominion Bank became uncollectable from McCaffreys; (e) as guarantor of this loan, the Appellant was required to satisfy the said debt, and did, in fact, discharge it by paying to the Bank the sum of $2,000.00 in the year 1972; (f) in the 1972 taxation year, the Appellant sought to deduct from his income the sum of $1,000.00 as an allowable capital loss, and the Respondent disallowed to the Appellant deduction of the said amount; In the Notice of Appeal the appellant states that: “Since the cost of the said shares in the said Corporation should equal the total amount paid by the Taxpayer, and since the proceeds of disposition is equal to less than the cost thereof to the taxpayer, the capital loss should be allowed as a deduction in the manner provided in Section 3 of the Income Tax Act.” ...

On September 15, 1968 he moved to the United States to accept employment with Gibbs & Hill, Inc, of New York, which company had offered him the position of mechanical engineer effective on completion of United States visa formalities. ... There is no doubt in my mind that, when the appellant accepted the offer of Gibbs & Hill, Inc, he intended to live permanently in the United States, and would have moved his family immediately if he could have sold his house in Scarborough. ...

We were told at the beginning of each year that on the basis of what we propose would be the amount of our business for that year, that they would automatically make available to us — for our customers and for us to attend and look after those customers — so many trips. ...

Kellough & Associates, Land Economists and Agricultural Consultants. ... The following figures are of some interest in assessing the appel- lant’s business known as W R Kellough & Associates: 1966 1967 1968 Total fees and disbursements billed $36,999 $39,791 $75,403 Professional fees (cash basis) $38,372 $42,649 $60,398 Net income $12,865 $11,995 $17,488 In 1970, the gross income increased to $105,000 of which 25% was income of an agricultural nature. ...