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From 1962 to 1969, by purchasing and reselling short-term shares, the appellant realized the following profits: 1962 $ 56,641.09 1963 261,243.77 1964 202,583.81 1965 120,183.50 1966 20,139,20 1967 79,385.68 1968 111,677.49 1969 264,951.53 While the appellant’s transactions were with some one hundred corporations, those involving the shares of Northern Exploration Ltd, Kelly-Desmond Mining Corp and Gaspésie Mining Co Ltd proved to be the most profitable for the appellant (see Exhibit R-2). ...

The following information is attached as an appendix to the notice of appeal: Appendix to an appeal to the Tax Review Board Mr Paul Laurent 1974 Employment income HYDRO-QUEBEC $17,779.68 University of Montreal 1,658.97 College du Vieux-Montréal 882.00 Saint Paul University, Ottawa 600.00 Allowance received (6(1)(b)(i)) 250.00 21,170.65 Professional income Quebec Order of Nurses (technical consultation and research) $ 250.00 University of Montreal (professional fees for consultation and research) 400.00 650.00 21,820.65 Deductible expenses relating to employment income Section 8(1)(a) 150.00 Travel expenses 2,885.99 Rental expenses 650.72 Supplies 450.00 Meal expenses 854.30 4,991.01 Deductible expenses relating to professional income Entertainment and advertising expenses 612.00 5,603.01 Adjusted net income $16,217.64 The amount of the expenses which the respondent disallowed and the taxpayer disputes is $5,603.01 ($5,603.01 less the $150 deduction allowed under paragraph 8(1)(a) of the Income Tax Act, SC 1970-71-72, c 63, as amended). ...

Taxable Income Year Net Income Revised 1969 $8,585 $6,019.40 1970 $8,111 $5,541.80 1971 $3,215 $1,464.94 1972 $4,215 $ 834.86 3.4 Those amounts added were income from “profit on sub-division in Nova Scotia”. ...

Facts The appellant is a solicitor practising his profession with the firm of Gambin, Bratty, Chiappetta, Morassutti, Caruso, Barristers & Solicitors, Downsview, Ontario. ...

In his income tax returns for the taxation years 1965 to 1973, both inclusive, he reported the rent received as income. 3.6 The residence at 33 Hazelhurst Drive had an original capital cost to the appellant of $22,703.50. 3.7 The appellant, when filing his income tax returns for the taxation years 1965 to 1973, both inclusive, represented to the Minister of National Revenue that the said property was depreciable property and claimed capital cost allowance on the said dwelling as being a Class 6 asset as defined in the Income Tax Regulations. 3.8 The fair market value on December 31, 1971 of the residence at 33 Hazelhurst Drive was $38,500. 3.9 The fair market value of the same residence on January 1st, 1974 (when the appellant commenced to occupy personally the said residence) was $47,000. 3.10 The total capital gain is ($47,000 — $38,500) $8,500. 3.11 The amount of capital cost allowance claimed by the appellant between 1965 and 1974 both inclusive is $12,167.17. 3.12 By assessment on December 17, 1976, the respondent included in the computation of the appellant’s income the amount of $12,167.17 as recapture capital cost allowance and $4,250 as taxable capital gain. 3.13 Following a notice of objection dated March 7, 1977, to the assessment, the respondent confirmed the said assessment by a notification dated June 13, 1977. 3.14 An appeal dated September 8, 1977, was lodged before the Tax Review Board. 4. ...

. * If I interpret the said Exhibit correctly, and understood her. submissions properly, people employed in railway, mining or public service in India, mostly receive a once-in-a-lifetime bulk pension on the termination of their employment or retirement, and in these catagories the bulk payment would amount to approximately $500 in Canadian money. ...

Mr Roméo Rivet paid his ex-wife $45 a week, for a total of $2,340 in taxation year 1969 and $2,307 in taxation year 1970; 5. for the next three years, he paid his ex-wife $100 a week, for a total of $3,220 in taxation year 1971, $5,200 in taxation year 1972 and $5,200 in taxation year 1973; 6. these payments were made after an exchange of correspondence between Mr Roméo Rivet and his ex-wife; /. ...

Victor Peters, in The Hutterians — History and Communal Organization of a Rural Group in Manitoba, wrote at page 14: The economic basis for the colony is provided by a highly diversified form of agriculture. ... When, however, the government requires of us what is contrary to our faith and conscience — as swearing oaths and paying hangman’s dues or taxes for war — then we do not obey its command. ... But what God hath not ordained, what is not regular taxation — that is given, not as a duty and as the ruler’s due, but is given because one doth so willingly and because one agreeth thereto or, in most cases, because one is pressed and coerced to do so. ...

In a letter accompanying the reconciliation, Mr Aubin stated that the balance sheets submitted were based on the appellant’s original financial statements prepared for tax purposes from 1960 to 1970; on subsequent information obtained from the appellant himself; on documents which were seized by the Minister of National Revenue in the course of the search, and on the inventory of safety deposit box No 320 — the source of the list of investments at June 30, 1970, the securities on which were included in the capital reconciliation (Exhibit I-4). ... The submissions by counsel for the appellant that safety deposit box No 320 was rented for Mr Real Groleau’s will (Exhibit I-9) — which the appellant took occasion to point out was an authentic deed, by which Mr Groleau, and that Mr Real Groleau bequeathed to his sister Mrs Bousquet any contents of any safety deposit box which he might have in a bank or caisse populaire — in no way refute the two statements by the appellant, and in the circumstances of this appeal do not constitute evidence that the contents of safety deposit box No 320 belonged to Mr Réal Groleau. ...

During 1966/7 the subject company bid and obtained a contract for the North Sydney Harbour in which the following losses were incurred: April 30, 1968 (785,365) April 30, 1969 (210,429) April 30, 1970 (63,764) (1,059,558) On March 31, 1969, Canadian Dredge & Dock Limited (now Ablemont) took an option to acquire the shares in the Gorman companies. ... In his reasons stated at 48 and 126 respectively, Mr J O Weldon, QC, as quoted by the respondent said: In a non-technical sense the term “business” appears to embrace such matters as — name, owners or shareholders, management, employees, premises, machinery, stock-in-trade, product, goodwill and financial standing. ... The evidence is that, in the loss application years, only some of the assets in the appellant’s Maritime operations were sold; the appellant continued to seek-out and to bid on tenders for its marine construction operations in the Maritimes; a marine construction contract was awarded and carried out by the appellant in Newfoundland in the loss application years; marine construction contracts on which bids were made could have been executed in the Maritimes, either with the appellant’s marine equipment already located in Halifax or with equipment transported from the company’s Great Lakes & St Lawrence operations, or through the accepted practice of renting marine equipment from competitors. ...