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Scott Davidson. 13 The Respondent called one witness, an evaluation expert — Mr. ...

During the first day of the resumption of the hearing of these appeals, the appellant Pierre Daneau, who was not represented by counsel, as I noted earlier, indicated that he wished to withdraw the part of his appeals dealing with the " income tax” element of each of the four assessments but that he wanted to pursue his appeals with respect to the assessment of penalties. ...

After three years Ronald Aylward and Fabian Aylward talked about making Ronald Aylward a shareholder at some time in the future to the extent of 10- 15 % and the wages paid to him would be the same as those paid to Fabian Aylward. ... The phrase used in subsection 7(1) is: (7) Subject to subsection (1.1), where a corporation has agreed to sell or issue shares of the capital stock of the corporation — There is no further definition of the term “agreed”. ...

Therefore in 1981 when the unit was used for 71 days, 25 of which were personal and 46 of which were business, the formula application was: 46 over 71 x 100 = 64.78 per cent of expenses deductible for business or $5,865.42 out of the total expenses of $9,023.73. ... & 3. (a) Gaining or producing income from a business and (b) Personal or Living Expenses In order for the appellant to be successful under heading (a) above, he must be able to satisfy the Court on a balance of probabilities that the expenses were incurred "for the purpose of gaining or producing income from a business" within the meaning of paragraph 18(l)(a). ...

Rayner & Keeler Ltd. (No. 2) 4, at p. 935, defined the requirements of issue estoppel as:... (1) that the same question has been decided; (2) that the judicial decision which is said to create the estoppel was final; and (3) that the parties to the judicial decision or their privies were the same persons as the parties to the proceedings in which the estoppel is raised or their privies... ... It will not suffice if the question arose collaterally or incidentally in the earlier proceedings or is one which must be inferred by argument from the judgment. [...] ...

.: — Dissension reigned in 1979 among the four shareholders of Les Industries S.L.M. ... According to the Minister, S.L.M. artificially or unduly created a loss of $ 1,000,000. ...

I use the term “ significantly profitable” because it appears from the Morrissey decision that the quantum of expected profit cannot be ignored and I take this to mean that one must have regard to the relative amounts expected to be earned from farming and from other sources. Unless the amount reasonably expected to be earned from farming is substantial in relation to other sources of income then farming will at best be regarded as a “ sideline business” to which the restriction on losses will apply in accordance with subsection 31(1). ...

Collier & Sons Ltd. (hereinafter called Collier) for the early part of 1982 and the latter part of 1985, and with Grolier Ltd. ... Block Research & Development (1981) Corporation v. M.N.R., [1987] 1 C.T.C. 253, 87 D.T.C. 5137 and my own decision in the case of Gibbs v. ...

Nomad Sand & Gravel Ltd., [1991] 1 C.T.C. 60, 91 D.T.C. 5032 (F.C.A.) do not apply. ... In Nomad Sand & Gravel Ltd., supra, the nature of the taxpayer's business did not give the taxpayer any on-going connection with its customers that would have allowed the taxpayer to demonstrate it had to provide future services. ... At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired ”... for the purpose of gaining or producing income from a business or property....” ...

McKean & Archibald Randolf, [1876] 16 N.B.R. 299; 3. M.N.R. v. Wardean Drilling Ltd., [1969] 2 Ex. ...