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It was established that losses and relevant figures were as follows: Taxation Year Gross Income Expenses Net Income (Loss) 1988 nil $17,719 ($17,719) 1989 $15,144 $43,821 ($28,377) 1990 $22,973 $64,109 ($41,136) 1991 $ 7,227 $39,232 ($32,005) 1992 nil $60,927 ($60,927) 1993 nil $51,450 ($51,450) The Appellant was also asked questions, on cross-examination on two occasions, respecting why he did not get rid of the boat. ...

Pursuant to paragraph 7 of the agreement, the appellant had no control over any amendment to the terms and conditions of the mortgage provided Clarfield agreed to any change sought by Gooden and participants representing at least 51 % interest in the loan to Gooden also agreed that such change, alteration, modification or variation be made. ...

At the same time, Budney requested the appellant to participate in a business corporation known as Affordable Tire & Auto Repair Ltd. ...

At 11 % interest, an increased expense of $6,600 is very close to the loss reported in each of the three years. ...

Appeals allowed. 1 At all relevant times, the Appellant was employed under contract by the province of On tario to assist in the production of various publications, etc. and appears to have worked at the offices of various Ministries. 2 A TD-1 form is generally provided to an employee by an employer to be completed for the purpose of providing the employee’s basic personal tax exemptions and other relevant infor mation to permit the employer to properly calculate the source deductions to be submitted to Revenue Canada. 3 Exhibit R-2. 4 ^he amounts referred to are those listed in the Appellant’s Exhibit A-4. 5 > Sheffield v. ...

. /?., [1998] 2 C.T.C. 2832 (T.C.C.), a decision of my colleague Bowman, at paragraph 18, in the factual background, he said:...Ms. ...

When the appellant and Musseau went into partnership it was under the name of W & M Company and business was carried on pursuant to a written partnership agreement. ...

It was pointed out that the 83 acres which he purchased of Lot 25 was not only in excess of what he wanted, but about 3 / times as large as Lot 20. ...

In support of such a position reference was made to several cases as follows: Southern v Borax Consolidated, Ltd, 23 TC 597; Algoma Central Railway v MNR, [1967] CTC 130; 67 DTC 5091; Toohey’s Ltd v Commissioner of Taxation (NSW), [1922] NSWSR 482; Kellogg Company of Canada Limited v MNR, [1942] CTC 51; 2 DTC 548; Hudson’s Bay Company v MNR, [1947] CTC 86; 3 DTC 968; Morgan v Tate & Lyle Ltd, 35 TC 406; Asamera Oil (Indonesia) Limited v Her Majesty the Queen, [1973] CTC 305; 73 DTC 5274; MNR v P P Drilling Ltd, [1976] CTC 58; 76 DTC 6028. ...

The legislation provided that, on the initiation of the taxation of capital gains, the market value of shares quoted on the London Stock Exchange be determined with reference to its market quotations on April 6, 1965, except where in consequence of special circumstances prices so quoted are by themselves not a proper measure of market value.” [1] In November 1964 serious discussions had begun between the chairman of Vickers Ltd and the taxpayer’s father, chairman of R W Crabtree & Sons Ltd contemplating the acquisition of all of the latter company’s issued shares by Vickers Ltd. ...