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. — LAURENTIAN LEASING INC. for the price of four thousand dollars ($4,000) per common share. ... Additional Additional Year Income Tax Tax Estate of Henri Giguère (later $ 91,580 — Yvonne Giguère (1965 20,000 $ 2,848 (1968 80,000 13,821 Marcel Giguere (1965 20,000 2,783 (1968 80,000 13,602 René Giguere (1965 20,000 2,710 (1968 80,000 13,611 Robert Giguère (1965 40,000 8,419 (later 154,193 — $585,773 $57,694 The taxpayers were advised four months ago of our intention to seek these directions but as yet they have made no representations. ... At this point we have a background report prepared for the Royal Trust Company by Clarkson, Gordon & Co, Chartered Accountants. ...

The position of the respondent was a requirement that the appellant submit proof that: —funds in the amount of the deduction claimed were in fact remitted to those people; — his father, stepsisters, and brother-in-law were dependent upon him within the meaning of that word as used in the Income Tax Act. ...

In its 1966 taxation year the Appellant sold 87,500 shares of Bonanza Explorations Ltd (NPL) to Columbia Securities Ltd as follows: January 31, 1966 28,985 @ $1.23 35,651.55 February 28, 1966 28,420 @ $1.23 34,956.60 March 31, 1966 30,095 @ $1.23 37,016.85 87,500 $107,625.00 11. ...

Fred James Blackwell (: MRN, [1949] CTC 362; 49 DTC 677: Cour de l’Echiquier; 2. ... Axler & Palmer Limited c MRN, [1973] CTC 2167; 73 DTC 119; 6. Donald B MacDonald c MRN, [1974] CTC 2204; 74 DTC 1161; 7. ... La Commission encore une fois ne se croit pas liée par ces facteurs mais constate néanmoins que l’appelant rencontre presque tous ces facteurs: —autonomie dans le travail (voir paragraphe 3.06 des faits); — connaissance et formation appropriées (voir paragraphes 3.02 et 3.05 des faits); — caractère personnel des rapports avec les clients: cela s’infère de la nature du travail même et de l’ensemble de la preuve; — caractère confidentiel des renseignements (voir paragraphe 3.05 des faits). ...

For the respondent: —Atlas advanced monies on behalf of the appellant by the year ended November 30, 1976 in the following amounts: January 19,1976 $ 3,288.60 April 8,1976 6,577.20 August 20,1976 55,906.20 $65,772.00 —The letter dated January 11, 1977 and the promissory note dated November 2, 1977 did not constitute a “bona fide arrangement” and neither were such arrangements “made at the time the loan was made”; —The letter dated January 11, 1977 and the promissory note dated November 2, 1977 did not constitute “repayment thereof within a reasonable time”. ... The letter and the note read as follows: January 11, 1977 Willetts Macmahon & Company 1901 Toronto Dominion Tower Edmonton Centre Edmonton, Alberta T5J 2Z1 Dear Sirs: This letter is to confirm that Atlas Electrical Supply Ltd has advanced funds to me for the purpose of purchasing a dwelling for my own occupation. ...

His evidence was that the appellant also has substantial interest in Crown Glass & Mirror Ltd which was more successful and continues to be operated by the appellant’s two sons. ... He had financial statements made for his meat business and Crown Glass & Mirror Ltd business, and reported their profit and loss in his tax returns. ...

With respect to the balance of the total amount for each year, to know in 1976 — $1,790.55; in 1977 — $1,837.50, these amounts represent interest paid on a personal residence mortgage and, consequently, these expenses are personal and living expenses and cannot be deducted by virtue of paragraph 18(1)(h) of the Act. ...

The appellant performed such work during 1978 as an employee of Coopers & Lybrand, a firm of chartered accountants. ... It is plain that authorized payments were insufficient to meet operating expenses, both as a result of insufficiency of the mileage rate paid by Coopers & Lybrand and as a result of limitations imposed by that firm on the circumstances in which it was prepared to pay mileage expenses to its employees. ...

The appeals were called at the time and place set forth in the Notices of Hearing — April 13, 1982 at Toronto. ... The Board granted the adjournment although counsel for the Minister objected strongly, reciting as reasons for objecting — the waste of time in preparing for the case, similar effort would have to be expended again in two or three months, and the costs already incurred. ...

In reassessing the Appellant in respect of his 1980 taxation year and thereby disallowing the deduction of $150 paid to the Appraisal Institute of Canada, the Respondent proceeded on the basis that the amount so paid was not one which “... Was necessary to maintain a professional status recognized by statute” since: (a) the Province of Ontario does not have legislation which recognizes a real estate appraiser as having a professional status, (b) the payment made was not necessary to maintain a professional status, and (c) the payment of such amount was not one required to be made to maintain the Appellant’s employment with the Department of Nation Revenue — Taxation. ...