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Sale No 2 — Martin to Woodlands — sold in April 1969 for $340,000 — 105 acres; 2. Sale No 4 — Campagnaro — sold in November 1969 for $350,000 — 99 acres; 3. Sale No 6 — Rutherford — sold in December 1973 for $310,000 — 43 acres. ...

In computing his net income for his 1974 to 1977 taxation years, the Appellant claimed in deduction of his income capital cost allowance (class 8) in the following amounts; 1974 — $5,555 1975 — 4,739 1976 — 3,906 1977 — 5,071 4. ... In making the said reassessments, the Respondent disallowed in part the deduction of capital cost allowance (class 8) as claimed by the Appellant in the following amounts; Amounts Amounts Amounts Year Claimed Allowed Disallowed 1974 $5,555 $ 981 $4,574 1975 4,739 1,080 3,659 1976 3,906 979 2,927 1977 5,071 2,730 2,341 and determined the Appellant’s income in the following manner; 1974 1975 1976 1977 $ $ $ $ Toral income previously assessed 27,636.00 35,874.00 40,112.00 39,096.00 Add Personal portion of automobile expenses 1,450.50 11,594.44 1,729.01 3,000.00 Taxable capital gain — 1,323.50 1,323.50 1,324.00 CCA disallowed 4,574.00 3,659.00 2,927.00 2,341.00 Revised total income 33,660.50 42,450.94 46,091.51 45,761.00 5. ...

Also filed were statements of income and expenses: Exhibit A-11: Buildings owned by appellant — 1977 — Income — $272,000. Exhibit A-12: Warehouses — 1979- gross income — $7,185,000 — — net income — $2,785,000. He explained that the income from the warehouses was much greater than that from the apartments and that they represented 60% of the invested capital; he further explained that in 1975, a very active year, supplementary letters patent had been obtained in order to confirm what had become a reality, namely, their vocation as leasing specialists, and that a new company, Roussin & Frères Ltée, was being set up for the sole purpose of going into the construction business. ...

Track and $ 6,000 $ 4,500 100 100 $ 6,000 $ 4,500 judge’s quarters 1,200 1,200 100 100 1,200 1,200 2. ... Inside track 40,000 (0.05) $ 2,000.00 (0.05) $ 2,000 5. Access road 21,000 (0.10) $ 2,100.00 (0.05) $ 1,050 6. Parking 100,000 (0.08) $ 8,000.00 (0.10) $10,000 7. 6” pipe aqueduct 1,100 (long) (5.50) $ 5,500.00 (2.08) $ 2,288 8. 4” inch pipe aqueduct 1,200 (long) (4.50) $ 5,400.00 (2.44) $ 2,684 9. 6’ high wood fence 4,000 (lin)(50%) (2.00) $ 4,000.00 (2.00) $ 4,000 10. 4’ high fence—sletcoh 336 (lin) (4.00 x 90%) $ 12.10 (2.71) $ 910 11. ...

Among other things, these notices show the following figures: Additional In- come Additional tax Penalties 1969 $27,824.89 $ 8,017.09 $1,522.00 1970 28,608.68 8,168.65 1,553.08 1971 30,568.18 8,762.04 1,685.01 1972 30,568.18 9,545.53 1,909.11 1973 18,419.29 4,827.18 965.44 1974 21,946.44 5,646.67 1,129.34 $157,935.60 $44,967.16 $8,763.98 3.05 At the beginning of the hearing, the respondent also filed en Hasse (Exhibit I-2) the opening balance sheet at December 31, 1968 and the closing balance sheet at December 31, 1974 with the calculation of capital and various schedules all of which formed the basis of the various assessments: Mr Gabriel Juteau Revised Statement of your Assets and Liabilities at December 31 1968 1974 ASSETS Current assets: Account receivable $ 775.20 $- Bank BCN no 1708 3,214.14 3,004.26 Bank BOM c/a — 122.97 Inventory 2,000.00 — $ 5,989.34 $3,127.23 Investments: Advance to Incarpool Inc. $- $41,647.66 Incarpool shares — 990.00 Term deposit BCN — 27,000.00 Term deposit BOM — 10,200.00 Bonds “Schedule 9” — 60,056.00 Shares “Schedule 8’’ — 13,109.00 $ — $153,002.66 Net Fixed Assets: Commercial land $20,000.00 $ 20,000.00 Commercial building 8,000.00 8,000.00 Chrysler automobile 3,800.00 5,886.00 Dodge 1971 Camper Truck — 3,/00.00 Ford Truck 1968 2,800.00 2,800.00 Camper Box (hand-made) 500.00 — Residence: 34, rue des Erables 12,300.00 12,300.00 Land: 34, rue des Erables 2,000.00 2,000.00 $49,400.00 $ 54,686.00 Total Assets $55,389.34 $210,815.89 LIABILITIES Mortgage on residence $ 5,847.39 $ 3,160.11 Balance of sale price on comercial land $12,000.00 — Total liabilities $17,847.39 $ 3,160.11 CAPITAL $37,541.95 $207,655.78 Total Capital and Liabilities $55,389.34 $210,815.89 Durette/rI Section 41-1 Room 1047 Montreal, February 15, 1977 Schedule ‘1’ 3.06 At the beginning of the hearing, the appellant put forward a number of points of disagreement (hereafter appearing under the letters A to K) with certain figures on the respondent’s opening and closing balance sheets. ... This list reads as follows: Shares Iso Mines $ 7,170.00 Neonex $ 3,641.00 Pan Can Petro $ 1,480.00 Great Northern Capital $ 1,215.38 Canadian Superior Oil $ 7,781.25 Inland Chemical $ 4,357.89 Vascan $ 4,515.01 Kirkland Townsite $ 4,383.99 Revenue Properties $ 4,410.00 Miscellaneous (approximate) $20,000.00 $58,926.64 3.24 Part of Exhibit A-5 was a supporting document issued by Doherty Roadhouse & McCuaig, a member of the Canadian Association of Stockbrokers. ... The inventory at the end of 1968 would therefore amount to $15,000 ($2,000 + $5,500 + $7,500). ...

(k) The appellant set up a company called the St-Léonard Flying Club Ltd for training young air pilots. 3.2 The financial statements of Commuter Air Services Ltd for 1969, 1970, 1971, 1972, and 1973 reveal the following: 1969 Income $ 7,850.00 Expenditure $36,787.01 Less personal expenses $20,868.61 $15,918.40 Losses $ 8,068.40 1970 Income $ 3,363.50 Expenditure $23,997.04 Less personal expenses $14,486.78 $ 9,510.26 Losses $ 6,146.76 1971 Income $ 4,764.00* Expenditure: General insurance $ 1,940.80 Bank interest and costs $ 2,812.00 Operating expenses $ 7,098.60 Depreciation $ 9,360.00 Wages $ 2,691.10 Travel $ 1,467.89 Rent $ 350.00 Professional fees $ 375.00 $26,095.39 Losses $21,331.39 ‘Included in this amount of $4,764.00 is an amount of $200 for personal use. 1972 1973 Income $ 1,201.50 Expenditure $11,945.70 $17,107.91 Less personal expenses Losses $10,744.20 $17,107.91.. — 3.3 The appellant maintained that he bought this plane in order to obtain an air carrier’s licence. ... It appears from Exhibit A-8 that in 1971 the total of hours was calculated at a rate of $60 an hour. 3.17 It appears from the appellant’s tax returns that in 1969 and 1970 the airplane was used for his personal ends roughly 60% of the time. 3.18 The company’s income and expenditure for the fiscal year from February 28, 1970 to January 31, 1971 were as follows: Income $ 6,045.65 Expenditure $52,716.72 Of the expenditure, wages amounted to $4,900.40 and the remainder was depreciation. 3.19 From October 1969 to January 30, 1970, the company’s income amounted to $430.80 whereas its expenditure was $9,446.21. 3.20 The respondent, through his notice of assessment dated May 27, 1974, disallowed the expenditure of $21,331.39 claimed by the appellant for his seven-passenger plane. 3.21 The appellant appealed to the Minister, filing a notice of objection dated August 22, 1974. 3.22 The Minister notified the appellant on March 7, 1975 that he upheld the assessment of May 27, 1974. 3.23 The appellant submitted a notice of appeal to the Board on June 2, 1975. 4. ... Paragraph 12(1)(a) and subparagraph 139(1)(ae)(i) state: 12(1) In computing income, no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from property or a business of the taxpayer... 139.(1) In this Act, (ae) “personal or living expenses include (i) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit... 4.2 The Board took notice of the following judgments, several of which were cited by counsel: — Her Majesty the Queen v Douglas C Matthews, [1974] CTC 230; 74 DTC 6193; — Ken Huband v MNR, [1974] CTC 2001; 74 DTC 1039; — MNR v Henry J Freud, [1968] CTC 438; 68 DTC 5279; — Donald Preston McLaws v Her Majesty the Queen, [1976] CTC 15; 76 DTC 6005; — Marcel Crépeau v MNR, 37 Tax ABC 280; 65 DTC 99: — Williamson v MNR, 1 Tax ABC 369; 50 DTC 147; — Alan R Needham v MNR, [1974] CTC 2078; 74 DTC 1057; — Riedle Brewery Ltd v MNR, 1939 SCR; [1938-39] CTC 312; 1 DTC 499-29; — F George Walker v MNR, 76 DTC 1224; — John S Stewart v MNR, [1964] CTC 45; 64 DTC 5023; — Onni Paju & Oiva V Paju v MNR, [1974] CTC 2121; 74 DTC 1087; — Ernest C Hammond v MNR, [1971] CTC 663; 71 DTC 5389; — R C Huffman Construction Company of Canada Ltd v MNR, 39 Tax ABC 172; 65 DTC 597; — William E Newton v MNR, [1969] Tax ABC 1174; 69 DTC 778; — D Carom v MNR, [1977] CTC 2085; 77 DTC 67. 4.3 Considering the appellant’s numerous activities, as shown by the evidence (paragraph 3.1), some would describe him as a “wheeler dealer’, while others would regard him as an “entrepreneur’’ or “captain of industry.’’ ...

During the 1975 taxation year, the employer reimbursed an amount of $735.42 to the appellant. 3.06 In filing his income tax return for the 1975 taxation year, the appellant claimed $388.88 as deduction computed as follows: Capital Cost Allowance: $2,541.00 Insurance & Registration: $180.00 Gasoline: $640.80 Oil & Lub & Filters: $ 84.00 Repairs & Maintenance: $180.97 $1,085.77 $3,626.77 Business Miles 4137 x $3,626.77 = $1,124.30 Total Miles 13,352 Less Reimbursement from Consumer and Corporate Affairs $ 735.42 Claimed $ 388.88 The amount of $640.80 for gasoline was calculated as follows on the basis of 15 miles per gallon and 0.72¢ per gallon: 13,352 = 890 x 0.72 = $640.80 15 3.07 Upon reassessment dated November 1, 1976, the respondent disallowed the amount of $388.88. 3.08 A notice of objection was filed on November 23, 1976. 3.09 The respondent answered on March 24, 1977, to confirm the reassessment. 3.10 The appellant lodged an appeal before the Tax Review Board on April 18, 1977. 4. ...

In assessing the appellant for his 1970, 1971, 1972 and 1973 taxation years, the respondent relied, inter alia, on the following presumptions of fact: (a) during the years in question, the appellant operated a transport business and was a partner in the operation of a bar in the city of La Salle; (b) the appellant did not file tax returns for the years in question within the time limits specified in the Income Tax Act; (c) on May 8, 1975, the appellant was required to file tax returns for the said years; (d) following this requirement to file, the appellant filed returns for 1970 and 1971 on July 4, 1975 and returns for 1972 and 1973 on July 22, 1975; (e) the appellant reported the following amounts of taxable income in computing his income for each of these years: Year Taxable amount 1970 $ 9,068.50 1971 $23,911.32 1972 $53,184.20 1973 $55,833.81 (f) the taxpayer failed to include his share of the income from the operation of the bar in the taxation years 1970 and 1971; $3,577.98 for 1970 and $7,616.94 for 1971; (g) the taxpayer therefore made a reconciliation of the appellant’s income and determined that his taxable income for the years in question was as follows: Year Taxable amount 1970 $11,546.48 1971 $29,828.26 1972 $53,184.20 1973 $55,833.81 (h) in a notice of assessment dated February 13,1976, the respondent applied a penalty under s 56(1) and s 163(1) of the Act, on the amounts of tax payable for each of the years in question: Year Tax payable Penalty (50%) 1970 $ 1,770.97 $ 885.48 1971 $ 5,829.06 $ 2,914.53 1972 $13,770.87 $ 6,885.44 1973 $14,695.09 $ 7,347.54 (i) the appellant wilfully attempted to evade payment of the tax payable by him by failing to file tax returns for the years in question. ...

Bank Records — Letter from Bank — Account Agreement — Hypothecation of Collaterals — Loan Authorizations 1979-81 — Application for Credit — Signing Authorities 7— Demand Loan Ledger F. ... Copies of Minutes — Regular Meeting H. Copies of Minutes — Annual Meeting I. ... Financial Plan — Proposal — Tabulation K. Statements — Annual L. Statements — Current Position M. ...

This new (revised) expense amount will be factored by + 10% for 1975. This indicates a 1975 operating statement of: Gross Income Projected $20,437.31 x 1.10 = $22,481.04 Plus $100/mos x 12 = $ 1,200.00 $23,681.04 Less Expenses $10,175.22 less — 514.65 609.28 150.69 116.00 $ 8,784.60 x 1.10 = $ 9,663.06 Net Income Projected (1975) $14,017.98 This projected net income, in turn, indicates a property value of: Net Income to Land & Improvments $14,018 Less Income Attributed to Land ($113,700 @ 7%)- 7,959 Income Imputed to Improvements $ 6,059 Capitalize @ 11% (7% plus 4% recapture) $ 55,082 Add Site Value $113,700 Property Value Indicated by Income Approach: $168,782 Say: $168,800 CORRELATION AND FINAL VALUE ESTIMATES Property Value Indicated by Cost Approach $172,200 Property Value Indicated by Income Approach $168,800 The property values found by the two approaches fall within a narrow range of $3,400 or approximately 2%, and both are considered of equal reliability in estimating the property value. ... An examination of the comparables used (finally those of Southward) and the results obtained is very illuminating when done in the following way: Adjustments Comparable Time Location & Physical Total % Total % # (Both) Southward Osland Southward Osland 1) + 6-20-55-14%-49% 2) + 7-10-45-3%-38% 3)-4-10-45-14%-49% 4) +19-10-45 + 9°/o-26% 5)-4-15-50-19%-54% Total Adjustment-41 %-216% Average Adjustment-8.2%-43.2% For the best comparables Southward could put forward, an average adjustment of-8.2% was required to bring about a relationship with the subject property as he saw it. ...