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There is a document on file to the effect that a commission of $1,000 was paid by appellant in connection with the sale of the property to Mr Gauthier. ...

Dear Sir: Your income tax returns for the 1968 and 1969 taxation years are presently under review and in connection therewith the provisions of Section 13 of the Income Tax Act, as set out hereunder, are brought to your attention. ...

In assessing the appellant, the Minister of National Revenue started from the premise that the appellant had received this $7,000 and then proceeded to make allowance for the disbursements totalling $2,246.54 which the appellant appeared to have made in connection with the execution of the said agreements. ...

Another explanation was given in connection with that purchase. The appellant apparently demanded that Continental repay the $142,500 and asked it for a loan of $269,500. ...

The taxpayer has paid the additional tax applicable, together with interest, and this appeal deals strictly with the penalty assessed in connection with the omissions of income for each of the years in question. ...

As applied to the subject law practice such assets. and liabilities include the law practice as a going concern, the name of the firm, the excellent client connection, the trained staff of junior lawyers and employees, the equipment, the favourable lease of the office premises, and so forth; all of which assets and liabilities were built up over the period of the appellant’s years of practice with this firm, and with his help, first as a solicitor employee and from 1956 as a partner. ...

In addition, I cannot leave out of consideration, when considering the character of the appellants’ business in connection with land, the speculative transactions upon which the appellants embarked with others where the avowed purpose was resale alone. ...

The two cases on which the appellant relied in that connection — M.N.R. v: Valclair Investment Co. ...

This witness agrees he recommended the contract entered into by Nexus and Nadka Services “as a way or manner of avoiding income tax in connection with Dr. ...

Then in 1971 he also acquired the Tradewind Edgewater Motor Hotel, and my recollection is that he paid $75,000 for it with $10,000 down, but it did not prove to be a successful operation and it too was sold. 6 I should say that, in all these transactions, the only evidence of a loss was in connection with the sale of the Quadra Motel, I believe it was, where he lost some $130, approximately. 7 The appellant has given evidence, has stated under oath, that his sole intention was to build the Empire Motel and the Townley Apartments for long-term investment, and that, in effect, his intention was frustrated by the fact that the Empire was too small and he was unable to purchase the land next door because it was part of an estate in which all the beneficiaries were not amenable to selling. 8 It is urged upon me by counsel for the appellant that I should accept this evidence of intention because the Crown has not seen fit to adduce any evidence to refute the intention alleged by the appellant and the appellant is supported by two character witnesses who have given evidence to the effect that he is a man of integrity and one to be believed. 9 In all these cases, it is very difficult to know what the intention is, because one cannot get into the mind of the witness and one must apply his evidence to the facts that are adduced before the Board in order to determine if there is some extraneous corroboration for the alleged intent. 10 There is no question in my mind that a witness such as this appellant is telling the truth as he sees it, and there is no attempt by the appellants in any of these cases, really, to try to mislead the Board or the Court. ...