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History With respect to IEM: — IEM operated River Glen Haven Nursing Home (River Glen), formerly Sutton Nursing Home Ltd, prior to December 31, 1971. ... Re: Enderes Goodwill $203,000 Licence $218,000< > 15,000< > Licence Total Included in Sale Agreement $218,000 $218,000 (2) One-half (/z) only applicable to appellant. (3) At December 31, 1971, according to respondent’: reassessment. ... To be consistent, therefore, counsel might agree that the ‘“‘per bed” value at October 31, 969 was $25,000 divided by 60 = $417 per bed. ...

Development of new reduction furnace — not yet successfully completed. ... Development of improved retort condenser — one new method was devised and adopted. ... Development of filter to eliminate flux — a satisfactory filter to remove flux from metal in sludge. ...

In computing his income for the 1976 taxation year, he sought to deduct the sum of $1,020.35 represented by the following items being financial literature with respect to the investment in securities: Bank Credit Analyst $ 275.00 Dow Theory Letters (4 years) 500.00 Consensus of Insiders 72.00 Trendway Advisory Service 18.00 The Chartist 85.00 Securities Research 88.00 $1,038.00 US Less US discount 17.65 $1,020.35 The Minister disallowed this deduction of $1,020.35 on the basis that the said amount constituted an outlay on account of capital relying, inter alia, upon paragraphs 18(1)(a) and (b) of the Income Tax Act, SC 1970-71-72, c 63, as amended. ... This issue has been dealt with many times in judicial decisions and I quote Jackett, P in Algoma Central Railway v MNR, [1967] CTC 130; 67 DTC 5091, at 134 and 5093 respectively: The “usual test’’ applied to determine whether such a payment is one made on account of capital is, “was it made “with a view of bringing into existence an ad- vantage for the enduring benefit of the appellant’s business” ”? See BC Electric Ry Co Ltd v MNR (1958), SCR 133 (58 DTC 1022, [1958] CTC 21), per Abbott, J at pages 137-8, where he applied the principle that was enunciated by Viscount Cave in British Insulated and Helsby Cables, Ltd v Atherton ([1926] AC 205), and that had been applied by Kerwin J, as he then was, in Montreal Light, Heat & Power Consolidated v MNR, [1942] S.C.R. 89 at 105 (2 DTC 535, [1942] CTC 1). ...

While the taxpayer has appealed both the 1977 and 1978 years, it would appear the relevant assessment applies only to 1978 — however, that again is not critical. ... And he used it in two ways — he used it for the deferral of the payment to the tax department, and he used it as a security payment to the trust company. ... However, it is my view that such an interpretation cannot be sustained and that the exact opposite must be the appropriate meaning — that the period of employment is deemed to have extended to and included the time at which payment is received, whether or not such employment itself had in fact continued and existed at the time of receipt. ...

SCHEDULE A Amount Amount Claimed Claimed Name Relationship 1975 1975 1976 Non-Resident Sham Kaur Sumbal Mother $646.00 $720.00 Surjet Kaur Mangat Mother-in-law $646.00 — Parminder Singh Mangat Brother-in-law $400.00 $720.00 Rajnant Kaur Mangat Sister-in-law $400.00 $720.00 Kaulesh Kaur Mangat Sister-in-law $640.00 — Hamir Singh Grandfather-in-law $646.00 $720.00 Rattan Kaur Grandmother-in-law $646.00 $720.00 Resident (Married equivalent) Gurdial Sumbal Sister $502.66 — ...

In 1968 he owned a business known as Town & Country Hairdressing and his full occupation was that of hairdresser. ... Between the years 1974 and 1977 the appellant reported the following income and expenses with respect to the raising of race horses on this property; Year Income Expenses 1974 $ 55 $ 3,097.00 1975 nil 11,268.19 1976 1,200 13,273.00 1977 2,000 16,587.00 The relevant section to be considered is section 31 of the Act which reads as follows: 31.(1) Where a taxpayer’s chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deductions in respect of expenditures described in section 37, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) /2 of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500, and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words “and before making any deductions in respect of expenditures described in section 37’’ were deleted, exceeds (ii) the amount determined under subparagraph (a)(i); and for the purposes of this Act the amount, if any by which the amount determined under subparagraph (a)(i) exceeds the amount determined under subparagraph (a)(ii) is the taxpayer’s “restricted farm loss’’ for the year. (2) For the purpose of this section, the Minister may determine that a taxpayer’s chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income. ...

Act — Case Law — Comments 4.1 Act The sections of the Income Tax Act involved in the case at bar are 5, 6 and 8. ... The Board concludes therefore that the entire $840 must be included in the appellant’s income. 4.3.2 Expenses of $393 — With regard to the expenses of $393 proved by the respondent, the Board notes that these were not ordinary expenses, because the appellant had broken ranks with the executive on policy and because he had even handed in his resignation. ...

In his testimony the buyer, Mr Keefler — and the appellant’s witness — stated that he had explained to the appellant that the company did not have the funds and that the bank’s reply to a loan application was pending. ... In his notice of appeal the appellant admitted that Lord Equipment did not issue him with a T4 slip, and Mr Keefler testified that he had not sent the cheque as he did not have sufficient funds in the bank to cover it — any more than he had sufficient funds to cover the cheques for $25,657.20 and $5,500 that he had issued at the appellant’s request. ...

Had it been so directed — despite the fact that the appellant no longer lived at the residential address or carried on business at the business address — and even despite the fact that the assessor was aware of these facts — it might well be that in the absence of any act on the part of the appellant to notify the Minister of a change of address, he would be bound by the sending of a notice to either of the addresses so given. ...

He calculated the percentage as follows: Business percentage 5 739 ^- = 61.7%, therefore personal portion is 38.3% 9,298 In 1978 the total miles put on his vehicle was 11,595 and the total business miles was 5,545. He calculated the percentage as follows: Business percentage 5,545 J-x = 47.8%, therefore personal portion is 52.2% 11,595 The relevant sections involved are subparagraphs 6(1)(b)(v) and (vil), paragraph 8(1)(h), subsection 8(2) and section 67 of the Income Tax Act, which read as follows: 6. (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (b) all amounts received by him in the year as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts forhisemployer, (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from (A) the municipality where the employer’s establishment at which the employee ordinarily worked or to which he ordinarily made his reports was located, and (B) the metropolitan area, if there is one, where that establishment was located, in the performance of the duties of his office or employment, 8. (1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (h) where the taxpayer, in the year, (i) was ordinarily required to carry on the duties of his employment away from his employer’s place of business or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was, by virtue of subparagraph 6(1)(b)(v, (vi) or (vil), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (g), amounts expended by him in the year for travelling in the course of his employment; 8. (2) Except as permitted by this section, no deductions shall be made in computing a taxpayer’s income for a taxation year from an office or employment. 67. ...