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There was no dispute concerning the payments which were made to these foreign companies: 1972 $44,500 1973 $ 5,500 1974 $46,500 1975 $17,500 No evidence was filed by the parties, but copies of the contracts in question were submitted to the Board. ...

L & F Holdings Ltd v MNR, [1975] CTC 2192; 75 DTC 150; 9. Marlee Investments Ltd v MNR, [1975] CTC 2189; 75 DTC 153; 10. ...

In the instant appeal the Court ordered the transfer and the conveyance of all the taxpayer’s interest in the matrimonial home to his estranged wife and further ordered that the taxpayer make all the mortgage payments until the mortgage was completely retired and discharged (Exhibit A-1, para 3 & 4). ...

The proceeds of disposition received by Appellant was $112,000 which was allocated as follows: $ 10,838.23 Land $101,161.77 Building 7. ...

Minister of National Revenue, [1978] CTC 2076, 78 DTC 1097 A W Prociuk (orally: November 15, 1977):—The appellant, Vincenzo Curcio, appeals from the respondent’s reassessment of his income for the taxation years 1967 to 1972 inclusive, on a net worth basis wherein the following amounts of unreported income were added in each taxation year and taxed accordingly: 1967 $5,108.86 1968 $5,397.41 1969 $9,055.35 1970 $2,778.37 1971 $3,925.88 1972 $5,199.23 The appellant was also assessed for penalties pursuant to subsection (2) of section 56 of the Income Tax Act, RSC 1952, c 148, and Subsection (2) of section 163 of the Income Tax Act, SC 1970-71-72, c 63, and section 17 of The Income Tax Act of the Province of Ontario as follows: Canada Ontario 1967 $199.32 $ 59.58 1968 227.93 66.56 1969 440.67 134.34 1970 127.12 32.33 1971 188.29 49.96 1972 286.09 100.19 The appellant was also assessed a late filing penalty for the taxation year 1972 in the sum of $106.76 but at the commencement of the hearing of this appeal counsel for the appellant advised that this portion of the appeal is being abandoned. ...

Counsel for the respondent cited a number of precedents: G H Chambers (Northiam Farms) Ltd v Watmough (HM Inspector of Taxes), 36 TC 711; Niessen v MNR, 25 Tax ABC 62; 60 DTC 489; No 485 v MNR, 18 Tax ABC 358; 58 DTC 69: Zakoor v MNR, 35 Tax ABC 338; 64 DTC 392: W J Kent & Co Ltd v MNR, [1971] Tax ABC 1158; 72 DTC 1018. ...

Alfred David Perry, dept, of Northern Affairs & National Resources, p.o. ...

On August 21, 1970 we authorized a loan of $52,000, funds from which were utilized for investment in F H Deacon & Co Ltd, Rampart Securities Ltd and Cerro Corp. ...

In other words, in that case the structures or the assets outside the mill became part of the mill — became part of the building. ...

The question to be determined, therefore, is whether or not the appellant was carrying on a business — and, indeed, whether what is commonly known as “playing the stock market” can be considered to be a business within the meaning of the definition contained in subsection 248(1) of the Income Tax Act. ...