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IRC v Fleming & Co Ltd, 33 TC 57; 9. Van den Berghs Ltd v Clark, [1935] AC 431; 10. Barr, Crombie & Co Ltd v IRC, [1945] SC 271; 11. Short Brothers Ltd v IRC, 12 TC 955; 12. ...

Et puis il a référé la Commission à de nombreuses décisions qu’il a divisées en deux catégories: Décisions favorables à l’intimé: William Richard Kay c MRN, [1971] Tax ABC 363; 71 DTC 285; Morley M Reider c MRN, [1970] Tax ABC 1178; 70 DTC 1746; Fox & Walker Ltd c MRN, [1969] Tax ABC 483; 69 DTC 388; Hugh Knox Ltd c MRN, [1973] CTC 2053; 73 DTC 50; Bainbridge Agency Ltd c MRN, [1971] CTC 878; 71 DTC 592; Vincent Doriste Moreau c MRN, Ex CR 198; [1977] CTC 2249; 77 DTC 153; Silverwood Dairies Ltd c MRN, 38 Tax ABC 379; 65 DTC 445; D Dupéré Inc c MRN, [1960] Tax ABC 198; 60 DTC 560. Décisions défavorables à l’intimé Francis David Moyls c MRN [1966] Tax ABC 411; 66 DTC 553; Halliday Fuels Ltd c MRN, [1960] Tax ABC 186; 60 DTC 541; Harbord Investment Ltd c MRN, [1970] Tax ABC 717; 70 DTC 1488; Simon Voyer <& Castelli Inc c MRN en appel. ...

The Facts 3.01 The appellant, as purchaser, entered into an agreement for sale dated September 17, 1975 with Mr Frank Remai and Mr Joseph Remai. 3.02 This agreement (Exhibit A-1) reads as follows: BETWEEN: FRANK REMAI and JOSEPH REMAI, both of Saskatoon, in the Province of Saskatchewan, to each an undivided one-half interest, — hereinafter called the Vendor OF THE FIRST PART, and WILLIAM SCHULTZ, of the City of Saskatoon, in the Province of Saskatchewan, —hereinafter called the Purchaser OF THE SECOND PART. ... A receipt was also produced as Exhibit A-3 in the amount of $10,000 signed by Remai Construction Company (1971) Ltd with reference: “Landscaping payment—3170 & 3176 Laurier St”. ...

However ‘‘an expenditure, for example, for the broiler farm would be reflected in the section of the general ledger for the broiler farm under the category of the expense” (page 74 of transcript, line 16). 3.12 Exhibits A-4 and A-5 show, among other things, the net income for the years 1973 and 1974 of the Brooder and the Broiler Farms: 1973 1974 1974 Brooder —Sales $277,951 $304,782 Gross profit 42,643 83,997 — Net income (loss) (19,361) 21,047 1973 1974 Broiler —Sales $575,297 $556,049 —Gross profit 86,975 107,704 — Net income (loss) (31,542) 739 3.13 After filing the 1972 income tax return on the accrual basis, the appelant amended it, electing to exclude inventories of poultry being raised on the Brooder Farm and the Broiler Farm as allowed by subsection 28(1) of the new Act. ...

Both witnesses had, by their company, Pearce, Kennedy & Associates Ltd, carried on the business of business valuators and brokers for a period of 14 months. ... A summary of the results which they arrived at is as follows: Summary of Share Valuation Estimated Value of the LPG Sales Division $1,350,000 Add: redundant assets —estimated value of the resource properties $1,969,439 —estimated value of the underground storage facilities 180,000 2,149,439 Less: allowance for tax costs @ 15% 322,416 1,827,023 Estimated fair market value of 2,339,402 shares $3,177,023 per share $1.36 say $1.40 This value of $1.40 per share is certainly realistic in view of the fact that the stock market price had risen to $1.65 per share in June, 1972. ...

In its 1975 fiscal year it loaned $79,000 to Yankel Ranch & Development Ltd (hereinafter called “Yankel”). ... The following advances were made to Yankel: $ 4,000 August, 1974 $35,000 September, 1974 $40,000 September, 1974 In each case the appellant received interest-bearing promissory notes. ...

For the respondent, the following assertions were made: —The appellant was not ordinarily required to carry on the duties of his employment away from his employer’s place of business or in different places; — Under the contract of employment, the appellant was not required to pay for the expenses incurred in the performance of the duties of his employment; —The appellant was reimbursed for all expenses incurred in performance of the duties of his employment; — During the relevant years, the appellant was in receipt of a travel allowance of 12¢ per mile in 1973 and from 15¢ to 18$ in 1974 to cover his automobile expenses: —Upon submission of vouchers the appellant was reimbursed all expenses other than those mentioned in the precedent subparagraph incurred in the performance of his duties; —The automobile expense which the appellant claims to deduct in computing his income for the relevant years are not reasonable and constitute personal and living expenses of the appellant. ...

These letters were both dated June 27, 1978, one relating to Mohinder Singh Grewal and the other one relating to Rajinder Grewal and were in the following forms: Exhibit A-4 June 27, 1978 Revenue Canada Taxation Federal Building 19 Lisgar Street, South, SUDBURY, Ontario Dear Sirs: RE: Support payments received from my daughter and granddaughter, Rajinder Grewal This is to certify that we have received the following support payments: 1974 $1,185 (Can) 1975 1,290 1976 675 Signed: (Signature) Karnail Singh Pancych Stamp ATTESTED Gurbax Kaur (Signature) (Signature) Notary Public for States of Sher Singh Pb & UP 26/7/78 (Signature) Notary (Notary Public) Jullundur, (India) Exhibit A-5 June 27, 1978 Revenue Canada Taxation Federal Building 19 Lisgar Street South SUDBURY, Ontario Dear Sirs: RE: Support payments received from my son Mohinder Singh Grewal This is to certify that we have received the following support payments: 1973 $1,100 (Can) 1974 1,160 1975 1,640 1976 1,500 Signed: (Signature) R S Grewal (Signature) Stamp Mohinder Kaur Grewal (Signature) Notary Mohinder Grewal in cross-examination said that Punjab preferred cash and that he had difficulty in cashing Canadian money orders in India, although he was shown, by counsel for the respondent, three money orders from the Royal Bank, dated September 22, 1976, September 22, 197 and November 24, 197, purchased by Rajinder Grewal and payable to presumed dependants in India, namely, her father and her mother. ... I can give no weight to the two letters drawn by Cook & Abois purportedly being shown before a notary, without any attestation clause. ...

Prior to the pertinent taxation years, the appellant’s income tax returns were prepared by H & R Block. ... In 1972, the appellant’s net business income reported by H & R Block was $16,391.24 and the appellant had to pay additional tax in the amount of $1,526.53. ...

Those five creditors were Fonthill Lumber Limited (Fonthill), Beamsville Block Limited (Beams- ville), Peninsula Ready-Mix and Supplies Limited (Peninsula), Burn- stein Brick Limited (Burnstein) and Transit Mixed Concrete & Builders Supplies Limited (Transit). ... Apparently in the spring of 1975 the respondent was examining the financial statements of the appellant and, as a result of inquiries, received a memorandum on the letterhead of Smiley, Scott & Ralph, Chartered Accountants. ...