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The following excerpt from the judgment of Cattanach, J in Admiral Investments Limited v MNR (supra) at page 319 [175, 5121] succinctly states my views in the case at bar: What must be looked at is what was done by the appellant with a view to asking the question in Lord President Clyde’s words in CIR v Livingston, 11 TC 538, at p 542: “... whether the operations involved (in the transactions of the company) are of the same kind, and carried on in the same way, as those which are characteristic of ordinary trading in the line of business in which the venture was made.” ...

What is “reasonable” is not the subjective view of either the respondent or appellant but the view of an objective observerwith a knowledge of all the pertinent facts: Canadian Propane Gas & Oil Ltd. v. ...

.] — per Lord Diplock, at page 326 The Abbot v. Philbin judgment was in no way put in question. ...

The process so far as then s 39 of the Income Tax Act was concerned was completed by Cattanach J in Vineland Quarries & Crushed Stone Ltd v Minister of National Revenue, [1966] CTC 69; 66 DTC 5092: “In my view the word 'controlled' in section 39(4)(b) contemplates and includes such a relationship as, in fact, brings about a control by virtue of majority voting power, no matter how that result is effected, that is, either directly or indirectly.” ...

The evidence is clear that the plaintiff did not extricate himself from the auto repair business in either 1978 or 1983, in part, because he could not afford to do so — the money made from employment in those businesses was being used by him to help establish his farm. ...

The second method of distinguishing Graham is the classical one — on the facts. ...

The bulk of judicial prose generated on the subject of fiscal residence has related to the peripatetic lifestyle of the leisurely wealthy — the jet setters of yesteryear. ...

Greenbaum (1957), 55 L.G.R. 129, he quotes: Anybody can apply for it — a member of the public who has been inconvenienced, or a particular party or person who has a particular grievance of his own. ...

Nevill & Co. Ltd. v. Federal Commissioner of Taxation a lump sum paid to get rid of an unnecessary director was held to be a revenue payment since •The purpose was transient and, although not itself recurrent, it was connected with the ever-recurring question of personnel" (per Dixon, J.). ...

The only business name displayed on the premises at 833 Central Avenue was the name "Brouwer Plumbing & Heating". ...