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Three letters, constituting Exhibit A-3, have been filed, and they show that companies by the name of Blyth & Company Incorporated, of Wall Street, New York; Morgan Stanley & Company, of New York City; and Paine, Webber, Jackson & Curtis of New York City, made independent valuations. ... Mr Haythe, of Morgan Stanley & Company, a highly qualified financier who was in charge of the group—or “team”, as he called it—that made the evaluation, gave his credentials, which were quite impressive. ...

They were all major shareholders in Ker & Stephenson Limited, a company incorporated under the laws of British Columbia, having its registered office in Victoria, British Columbia. The said agreement reads as follows: Whereas, the shareholders are the major shareholders in Ker & Stephenson Limited, a company duly incorporated under the laws of the Province of British Columbia, and having its registered office at 680 Broughton Street, in the City of Victoria, in the Province of British Columbia, (hereinafter referred to as the “Company”); And whereas, it is the desire of the shareholders that upon the death of any of them, the shares of common stock of the company which are owned by such deceased shareholder at the time of his death, shall be purchased by the surviving shareholders, except the said Alfred John Ferguson Roberts; And whereas, the shareholders have requested the secretary for the time being of Ker & Stephenson Limited, presently Robert T. ... (c) The surviving shareholders shall pay the purchase price of the said shares to the personal representative of the deceased shareholder, as follows: (i) A sum equivalent to one-third (%) of the value thereof shall be payable to the personal representative of the deceased shareholder, in cash, within six (6) months following the death of the deceased shareholder, provided however, that in the event the Estate Tax assessment has not been made and accepted by the personal representative of the deceased shareholder, within the said six (6) months, the required one-third (‘/3) payment shall be made upon acceptance of such assessment by the personal representatives. ...

On or about the end of January 1962 the group incorporated Buttle Lake Mining Company Limited (NPL) and sold its interest in the claims to the company — each member receiving 162,500 shares, all of which were placed in escrow. ... At about the same time C M Oliver & Co Ltd underwrote the sale of shares of Buttle Lake to the public and further underwritings by this stock brokerage firm were made in Buttle Lake’s shares in subsequent years. Number^ of Shares Proceeds 1963 14,300 $11,326.00 1965 11,500 4,197.50 1966 17,638 14,798.08 The appellant was at all material times a stock salesman and subsequently a partner in C M Oliver & Co Ltd. ...

Minister of National Revenue, [1978] CTC 2895, [1978] DTC 1637 Guy Tremblay [TRANSLATION] — This case was heard at Chicoutimi, Quebec, on October 17, 1977. 1. ... The respondent cited paragraphs 8(1)(e) and 8(1)(g) of the new Act: (e) Expenses of certain railway company employees employed away from ordinary residence or home terminal. — amounts disbursed by the taxpayer in the year for meals and lodging while employed by a railway company (i) away from his ordinary place of residence as a relieving telegrapher or station agent or on maintenance and repair work, or (ii) away from the municipality and the metropolitan area, if there is one, where his home terminal was located, and at a location from which, by reason of distance from the place where he maintained a self- contained domestic establishment in which he resided and actually supported a spouse or a person dependent upon him for support and connected with him by blood relationship, marriage or adoption, he could not reasonably be expected to return daily to that place, to the extent, that he has not been reimbursed and is not entitled to be reimbursed in respect thereof; (g) Transport employee’s expenses — where the taxpayer was an employee of a person whose principal business was passenger, goods, or passenger and goods transport and the duties of the employment required him, regularly, (i) to travel, away from the municipality where the employer’s establishment to which he reported for work was located and away from the metropolitan area, if there is one, where it was located, on vehicles used by the employer to transport the goods or passengers, and (ii) while so away from such municipality and metropolitan area, to make disbursements for meals and lodging, amounts so disbursed by him in the year to the extent that he has not been reimbursed and is not entitled to be reimbursed in respect thereof; These sections cannot apply since one of the required conditions is that the employer be a railway or transport company. ... The Board also considered the other paragraphs of section 8, but none of them can permit the appellant to. deduct any expenses in addition to those he has already deducted under paragraph 8(1)(a): (a) Employment expense deduction. — a single amount in respect of all offices and employments of the taxpayer, equal to the lesser of $150 and 3% of the aggregate of (i) his incomes for the year from all offices and employments (other than the office of a corporation director) before making any deduction under this section, and (ii) all amounts included in computing his income for the year by virtue of paragraphs 56(1)(m) and (o); Thus in applying the Income Tax Act for the years in question, the Board has no choice but to uphold the assessments issued by the respondent. 5. ...

Contentions In his notice of appeal, the appellant asserted that: — In 1974, he and Allen E Duke were operating a business venture in relation to imported European antiques. —The profits from such a venture were to be divided equally with Duke. — Duke was to do the buying and selling. — He (the appellant) arranged two letters of credit for the purpose of purchasing antiques in Europe which became part of the inventory of the business venture. —As antiques were purchased by Duke, sums were drawn on these letters of credit in order to pay for the antiques so purchased. — Drawings on the aforementioned letters of credit were as follows: December 14, 1973 $ 142.00 December 18, 1973 8,500.00 December 27, 1973 2,000.00 December 28, 1973 2,672.92 January 18, 1974 20,092.00 January 24, 1974 66.85 January 24, 1974 6,685.08 February 11, 1974 133.15 $40,292.00 —The business venture was unsuccessful and the appellant suffered a business loss in the amount of $22,184.16. — In conjunction with various business activities he expended in 1974 $2,025.16 in relation to business promotion. ...

(c) The upward adjustment referred to in the immediately preceding paragraph hereof was calculated as follows: Gross proceeds of disposition $158,950.00 Less Minister’s appraisal 8,032.79 Less outlays and expenses 1,791.68 Capital gain $149,125.53 Taxable capital gain (/2 of $149,125.53) $ 74,562.76 Taxable capital gain reported 10,770.99 Adjustment $ 63,791.77 (d) The appellant’s position as to the disposition of his capital property in 1976 and the amount of taxable capital gain is as follows: Gross proceeds of disposition $158,950.00 Less Valuation Day value of appellant’s Capital property as per appellant’s appraisal 135,616.35 Gross gain 23,333.65 Less outlays and expenses 1,791.68 Capital gain (gross) $ 21,541.97 Taxable capital gain (1/2 of $21,541.97) $ 10,770.99 The respondent reassessed the appellant on a taxable capital gain of $74,562.76 on the following assumptions of facts: 2. ... At the hearing, counsel for the appellant filed two appraisal reports, one prepared by Mr P W Bowman of Price Waterhouse & Co and the other by Mr R Carlin, business evaluator with Revenue Canada. ... Mr Aldridge was critical of the Price Waterhouse & Co’s report because the latter did not give adequate weight to the option agreements especially as in the case at bar of a private company; and also because it appraised the company instead of shares which were very restricted. ...

According to the evidence, four individuals — Mr Douglas J Lemery, a businessman; Mr Kenneth J Davis, a real estate agent; Mr Earle A Morrison, an industrial designer; and Mr Robert W Siddall, an architect — purchased the land, paying $10,000 down and $40,000 on completion of the titles, and then transferred it for the same price to the appellant company. Mr Lemery testified that he and his brother had been in the motel business in Seattle for a number of years — operating between 15 and 20 motels. ... He referred the Board to a Supreme Court judgment — Thomas Campbell v MNR, [1953] 1 S.C.R. 3; [1952] CTC 334; 52 DTC 1187 — to say that even though the express intention is important it is not conclusive and the course of conduct should also be examined. ...

Mr and Mrs Latta do not submit expense accounts for purposes of reimbursement of these promotional expenditures. — Both Mr and Mrs Latta are remunerated in the form of salaries for the above activities as well as for the management of the company. — The promotional expenditures are properly deductible for income tax purposes as evidenced by the consistent annual increases in sales volume. — Mrs Latta is a bona-fide employee and is engaged in gainful employment. ... The respondent contended that: (for the Company) — the appellant did not make the outlays of $3,600, $3,991, $5,130.65, $6,604.20 and $6,604.20 for the purpose of earning income from a business. — Mrs Latta did not carry on any business purpose in her use of the leased car. (for Latta) — the advances from Active and the portions of the leased auto payments were properly included in the appellant’s income. ...

This question turns on whether the Reigate School of Art & Design is a designated educational institution within the meaning of paragraph 110(9)(a) of the Act. ...

In addition, the Minister agreed that: — in December 1976, the Appellant and Danzo sold an undivided one half interest in the undeveloped Block 1 Project to Robert William Lineham and Terrence John Lineham (hereafter called the “Linehams”) (or the Builders). — in December 1977, the Appellant and Danzo reacquired one-half of the Linehams’ undivided one-half interest in the partially developed Block 1 Project and sold to them the partially assembled and undeveloped Block 2 property. — in September 1978, the Appellant and Danzo entered into an Option Agreement with the Linehams to reacquire Block 2. — the Appellant and Darzo sold a portion of their interest in the Block 1 Project in November and December 1978 to various purchasers. ... For the respondent: — It was never the Appellant’s intention to retail all his interest in the property in question; — the Appellant and Danzo were at all material times experienced developers with a history of involvement in real estate ventures and as such had knowledge of the real estate market; — the Appellant and Danzo’s financial position and their equity in the Block 1 and Block 2 properties were not such as to force them to sell a large portion of their interest in the said properties; — the Appellant and Danzo acquired the Block 1 and Block 2 properties with the intention of assembling, developing and selling a major portion of the project in the general course of a business transaction; — in the alternative, the acquisition and development of the properties was a speculation in which the possibility of turning a portion of their interest in the properties to account for profit at an early stage was a major motivating factor. ... These transactions were explained to the Bord as founded in the cost overruns on Block One — eventually the total cost was established in 1978 as some $3,340,570 ($940,570 over the RTL estimate of 1976), and the formal demand from the Royal Bank for payment of a $561,000 loan made to the appellants in connection with the project arising out of the pre-1976 property acquisitions. ...