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William O’Kane & Associates Insurance Agency Inc (“the company”) from 1974 to 1977, he was not obliged to include in his personal income the commissions paid by Crown Life to the company during the said years. ... A listing was placed in the Windsor telephone book indicating the name of J William O’Kane & Assoc Insce Agency (Exhibits A-9 and R-3, SN p 58); 6. ... Snook v London & West Riding Investments Limited, (1967) 1 AER 518. 26. ...

This counter-offer was not accepted by N & Z Investments Limited. 18. ... Capital Gain $ 2,926. Taxable Capital Gain $ 1,463. The taxable capital gain was reported for tax purposes as follows: (a) Donato Romano $648. (44%) (b) Gilda Gabriele $163. (11.2%) (c) Emilia Gabriele $163. (11.2%) (d) Elisa Latini $163. (11.2%) (e) Marie Latini $ 54. (3.7%) (f) Max Glassman $109. (7.5%) (g) Pietro Ciccocelli $163. (11.2%) 21. ... Whether an offer to purchase was received and a counter offer made by the appellants in 1970 is not material to the issue unless a secondary intention of selling the property — if the original plan were to fail — can be clearly shown to have existed at the time the property was acquired and that the sale of the property had been a motivating factor in their acquisition of the land. ...

Act — Case Law — Analysis 4.01 Act The provisions of the Income Tax Act on which the notices of assessment were based are subsections 153(1) and 227(9). ... HMQ v Coopers & Lybrand Limited, [1980] CTC 367 and 406; 80 DTC 6281; 7. ... The Board has concluded therefore that the penalty in respect of the principal of $5,089.65 ($3,957.50 — 1978 and $1,132.15 — 1979) should be upheld. ...

In assessing, the respondent relied upon the following assumptions of fact: — Pour les années d’impositions en cause, soit 1968 à 1973, l’Appelant n’a pas déclaré tous les montants de revenu qu’il devait déclarer; —Ces montants de revenu totalisent une somme de $132,722.82, telle que calculée par conciliation de capital, telle que produite à la présente Réponse pour valoir comme si récitée au long; — L’Intimé ajouta donc une somme de $17,327.46 de revenu pour chacune des années d’imposition de 1968 à 1971 et un montant de $31,706.48 pour chacune des années 1972 et 1973 et émit une nouvelle cotisation en conséquence. — During the taxation years in question, 1968 to 1973, the appellant did not declare all the amounts of revenue which he should have declared; —These amounts of revenue totalled $132,722.82, as calculated by “reconciliation of capital” (not attached—but they were: 1968 to 1973—$69,309.86 and 1972 and 1973—$63,412.96). ... —Au cours des années 1968 à 1971, (’Appelant a gagné une somme de $10,000 en jouant aux cartes. — During those years an amount of about $60,000 was left with the appellant in order that he would be the trustee of it. — During those years the appellant contracted a loan of approximately $62,606, which in turn he loaned to a third party, namely ‘‘Bar Horizon Inc”. — During the years 1968 to 1971, the appellant gained an amount of $10,000 by playing cards.) ... Despite the reluctance of Mr Daoust to sustain one position, / am satisfied that he received the cash from Charron at the time of endorsement, and that he received $1,000, not $1,175, which was the face value of the cheque. ...

In substance, those provisions appear in the agreement, paragraphs 1, 2, 3, 6 and /. 3.11 The witness, Mr Bruyneel, said that he was not present when Mr Mahar and Mr Butcher signed the agreement on March 23, 1974. ... (f) He arranged the entries and the figures so that earnings had been paid in the amount of $12,746.05 in 1974; (g) in making his own papers (Exhibit A-Q-1) he had on hand the working papers of Mr Buyneel (Exhibit A-M-2) (SN p 89), but he did not have the corporate records (SN p 97); (h) He did not agree that the figures made by Mr Bruyneel pertained to the agreement (Exhibit A-M-1) “So we took the steps we felt necessary to follow the terms of the agreement” he said (SN p 89); (i) “We felt the agreement wasn't particularly clearly constructed so we contacted Wayne, as well as contacting MacGillivray & Company and Wayne’s interpretation was not the same as the interpretation that MacGillivray & Company had put on it; and our interpretation of the agreement bore out what Wayne (Butcher) said, and that is how we recorded the items in the books.” ... This balance was paid and Butcher received Mahar’s former shares (paragraph 3.12—h & i). ...

. — By an agreement dated July 4, 1969, the taxpayers as equal partners purchased Part of Lot 3, 4, and 5, Concession 2, in the Township of Hope, know as the Belmont Farm, comprising 215.244 acres more or less for the amount of $100,000 (the property). ... The cost of this preparation initially was in excess of $900. — Immediately after acquisition, the taxpayers began advertising the property as Belmont Park, a showmobile area. ... —On February 9,1972, the building was totally demolished in a fire, with the loss of the entire investment therein. — Following on from the fire, and a loss of the proposed principal residence of the taxpayers, it became essential to reconstruct or construct a residence. ...

Net income declared $403,272 Deduct: Taxable capital gain reported 313,898 $ 89,374 Add: Income from expropriation and sale of Markham property $4,163,240 Less: Reserve under Para. 20(1)(n) 68,332 $4,094,908 Revised net income $4,184,282 Contentions It was contented on behalf of the company that: — All of the shares of the taxpayer are beneficially owned for members of the family of von Thurn and Taxis (hereinafter referred to as “the family”). ... —On March 27, 1975 an agreement was reached with the company establishing a consideration in the amount of $1,529,100 for the properties in Concession 10 which had been expropriated. — By an agreement the properties in Concession 9 were sold to the Province of Ontario on March 27, 1975, for a total consideration of $3,394,100. —As a result of the said expropriation and sale to the Province of Ontario on March 27, 1975, the company realized a profit (after certain expenses) in the amount of $4,163,240. — During the period that the company owned the said properties, it realized no net income or profit from the rentals of the said properties. ...

That exhibit is reproduced herein: We are here as your friends & we know that the agency is in terrible strain and this has been very hard on you & your family. ... I’m going to quit—which may be of great relief to her, and at that time you can give us your resignation & retain your dignity. ... I want you to know how much I & the board admire you & your capabilities, but it was the rule of the board that I have to ask for your resignation. ...

Page 11, which indicated a basis for the deposit, reads as follows: SCHEDULE A — DOUBLE DUTY SHORT PAID $316,670.36x2 $633,340.72 PLUS SALES TAX SHORT PAID 288,131.68 921,472.40 SCHEDULE B — DOUBLE DUTY SHORT PAID $2254.35 x 2 4,508.70 PLUS SALES TAX SHORT PAID 2,074.02 6,582.72 SCHEDULE C — DOUBLE SALES TAX SHORT PAID $2222.19 x 2 4,444.38 SCHEDULE D — DOUBLE DUTY SHORT PAID $6919.04 x 2 13,838.08 PLUS SALES TAX SHORT PAID 6,011.85 PLUS EXCISE TAX SHORT PAID 2,766.30 22,616.23 TOTAL 955,115.73 Following receipt of the document, the appellant, through its officers and solicitor, had two meetings in Ottawa with the then Deputy Minister of Customs and Excise and other officers of the Department. ... The first case was Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] Ex CR 274; [1970] CTC 99; 70 DTC 6085. ... It can readily be seen that the instant appeal is in no way similar to the Olympia Floor & Wall Tile (Quebec) Ltd case. ...

.; 5 the circumstances which caused the sale; 6 intention. 4.3.2 Canadian precedents consider almost the same factors: 1 intention; 2 the relationship between the transaction and the taxpayer’s business; 3 nature of the transaction and goods involved in it; 4 number and repetition of transactions: 5 the objects of the corporation. 4.3.3 In the case at bar, the factors to which the parties refer are the following: (a) intention: — the intention was to invest, says the appellant; —, the purchase was made with a view to resale, says the respondent; (b) duration of ownership: — the period of one month between purchase and sale is indicative, says the respondent, of commercial profit; — circumstances made it necessary to sell so quickly, explains the appellant; (c) partnership with Les Entreprises Marcal Inc: — Les Entreprises Marcal Inc has as its object the purchase and sale of land; the appellant does not hold shares in Les Entre- prises Marcal Inc; she is not a person connected with this company and is a legal person independent of the company; (d) number of transactions: — this is the appellant’s only transaction; according to the respondent, it is at least an adventure in the nature of trade (paragraph 139(1)(e)); (e) object of the sale: — by its nature a piece of land is usually an object of investment, especially if one plans to set up a campground on it-^however, it can be an object of trade if the investment was only a pretext, or if the buyer changed his mind too readily. 4.3.4 At first glance, what strikes the Board is perhaps this very readiness with which the buyers suddenly changed their minds about the campground and decided to sell. ...