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L’intimé a produit comme Pièce I-4 une lettre adressée au Ministère du Revenu national par Tibor Jeledi & Co en date du 15 février 1974, et soutient qu’il s’agit-là d’une preuve que l’appelant voulait écarter Attila des services du “joint venture”. Ladite lettre se lit comme suit: Tibor Jeledi & Co. Chartered Accountants—Comptables Agrees 5775 Victoria Ave., Suite 220 Montreal, Quebec H3W 2R4 Feb. 15, 1974. ...

Facts By notarial deed dated December 30, 1971, the appellant and his brothers Denis and Pierre-Paul accepted an offer by their father, Fernand Blais, to sell 165 common shares in Fernand Blais & Fils Ltee (hereinafter referred to as “the company”) for the sum of $300,000 payable in instalments at the rate of $15,000 a year. ... The respondent emphasized that the presentation of evidence determining the value of the shares of Fernand Blais & Fils Ltée clearly rested with the appellants, and it was for them to establish to the satisfaction of the Board by valid evidence that the valuation made by the respondent was erroneous. ...

In these assessments the Minister increased the appellant’s reported income as follows: Year Added to income Penalty 1970 Interest income $322.80 $ 19.26 Interest expenses: Mr Legault 900.00 Mr Giroux 810.00 $2,032.80 1971 Interest income: Mr Andrews 756.88 Mr McGowan 700.00 131.15 Mr Penchèvre 875.00 Realization of profit: McWhiter & Paule Delorme 2,908.50 Loss of debt refused 2,508.50 7,348.88 1971 Interest income Mr McGowan 700.00 Mr Penchevre 1,000.00 1,700.00 141.51 1973 Interest income Mr McGowan 700.00 Mr Penchèvre 1,000.00 Profit realized on sale of land 10,912.57 Recapture of capital cost allowance 5,000.00 17,612.57 1,060.84 1974 Profit realized on the sale of part of lot 151(20) 2,605.33 Profit realized on the sale of part of lot 32 29,124.76 31,730.09 Minus: Taxable capital gain reported 251.25 31,478.84 2,643.92 The Estate of the late J Alzire Tardif appealed from a tax assessment for 1971 in which the Minister increased the reported income by $106,861.69 in “net business income”. ...

Lots 1, 2, & 3 plus common use of Lot 4 (for parking), Block 37, Plan #22870 & #51315 in the town of Banff, Alta. ...

. $ 216.54 —Spence Estate 17.04 —Spence-Hughes-Spence 1,004.61 1,238.19 Depreciation —Clinic Buildings 5% $47,990.55 2,399.55 8,068.45 Operating Profit $11,578.11 Less—Reserved For Income Taxes 2,923.47 Net Profit For Year $ 8,654.64 From the above points it may reasonably be concluded that the operation of the appellant could be conducted, in theory at least, by the deposit in the appellant’s bank account of twelve rental cheques from the lessee, and perhaps a thirteenth for the portion of the municipal taxes; and by the issuance of eight cheques from the bank account, one each for municipal taxes, insurance, accounting, Ontario corporation capital tax, three for mortgage interest, and finally one, if necessary, for corporation income tax. ...

The option states:. shall be payable Forty Thousand Dollars ($40,000) in cash or by certified cheque to W H Bosley & Company Limited, agents for the Vendor... ... The concluding paragraph of the option states: THE Purchaser agrees to pay to W H Bosley & Company Limited the commission for its services in the negotiation of this transaction if, as and when the transaction is fully completed. ...

If the respondent is right, the appellant company would have to pay the following amounts of income tax: 1968 $ 291,596.49 1969 191,983.44 1970 336,513.92 At the hearing, three witnesses were heard: (1) Mr John Arnold Tory, director and solicitor of Scottish and York Holdings Limited and its subsidiaries; (2) Mr Richard Douglas Abbott, CA, officer and auditor and now vice-president and secretary-treasurer of all the Canadian companies; (3) Mr Kenneth Hugh Doyle, president and director of all the Canadian companies. ... As to the dual residence issue, he referred the Board to the following cases: (1) Bedford Overseas Freighters Ltd v MNR, [1970] CTC 69; 70 DTC 6072; (2) Swedish Central Railway Co Ltd v Thompson, [1925] AC 495; (3) Bullock v Unit Construction Co Ltd, 38 TC 712; (4) Tara Explorations & Development Co Ltd v MNR, [1970] CTC 557; 70 DTC 6370; [1972] CTC 328; 72 DTC 6288; (5) The American Thread Co v Joyce, 6 TC 1 (KB and CA); 6 TC 163 (HL); (6) Mitchell v B W Noble Ltd, 11 TC 372; [1927] 1 KB 719. ...

By notice of appeal dated November 26, 1973 the appellant company appealed from the said assessments whereby the Minister of National Revenue had disallowed the deduction of the following amounts paid as interest on money borrowed from Gulfstream Insurance Limited, a company incorporated in the Bahamas, and in the relevant years a wholly-owned subsidiary of Distillers Corporation- Seagrams Limited: for 1967 $ 615,702 for 1968 $1,016,353 for 1969 § 930,747 The principal issue to be decided in this appeal is whether these interest amounts were properly disallowed by the Minister on the ground that they did not fall within the meaning of paragraph 11 (1)(c) of the Income Tax Act as it read at that time. ...

The admitted facts show that for the year under appeal the appellant Russell Snow was an unenfranchised Indian and a member of the Caughnawaga Indian Band within the meaning of the Indian Act, RSC 1952, c 149; that he was a resident of Canada within the meaning of the Income Tax Act and also a resident of Caughnawaga; that Caughnawaga is an Indian Reserve within the meaning of the Indian Act: that in assessing the appellant for the above-mentioned taxation year the Minister of National Revenue, in the computation of his income, added the amount of $9,150.07 received by the taxpayer for services performed by him outside the Caughnawaga Indian Reserve for the following employers whose construction sites were located in the United States: Whitehead & Kales Ltd (Can) $2,269.05 Edward J O’Leary (Can) 733.25 Standard Erecting Co Inc (Can) 1,331.17 Ebasco Services Inc (Can) 1,702.23 BA Roy Steel Erectors Inc (Can) 3,114.37 $9,150.07 In addition to the above admissions, Russell Snow testified that he was raised in Caughnawaga, has lived there most of his life, and that is where he supports his wife and his two children and where most of his recreational activities take place. ... The responsibility of the Parliament of Canada in relation to the international administration of the life of Indians on reserves is succinctly stated by Rand, J, in St Ann's Island Shooting & Fishing Club Ltd v The King, [1950] 2 DLR 225 at p 232, [1950] S.C.R. 211, where he was dealing with the effect of s 51 of the Indian Act, RSC 1906, c 81, in relation to the “surrender” of lands on Indian reserves and said: “The language of the statute embodies the accepted view that these aborigines are, in effect, wards of the state, whose care and welfare are a political trust or the highest obligation.” ...

There were three alternatives open to Mr Thompson, namely: (1) accept the offer ‘and sell the shares — thus realizing a capital asset; (2) refuse the offer, wait to receive the dividend and be fully taxed on it; (3) sell the shares to a broker and then buy them back ex dividends. ... Mr Renouf did not negotiate the arrangement with Scotia Bond Company — this was done by Mr Cowan. ...