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In 1961, prior to the rezoning referred to, and in connection with a proposal for extensive development of this and other land, probably requiring a large, well financed developer, defendant did advise one Hanson, a town planner, that he could deal with his, Hanson’s, English interest on a possible purchase but no terms or bases were set. ...

The main sections of the Act concerned in this list, as in the case at bar, are paragraph 12(1)(a) and subparagraph 139(1)(ae)(i) of the old Act, which read as follows: 12. (1) In computing income, no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from property or a business of the taxpayer, 139. (1) In this Act, (ae) ‘‘personal or living expenses” include (i) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit, The basic problem is therefore whether the publication of the taxpayer’s books is a “business carried on for profit or with a reasonable expectation of profit’’. ...

However, it was possible to use the first type in a masonry construction although it was not usual to do so as special connections would have to be provided to anchor the frame to the masonry. ...

He was a professional trader in the field of securities and his analysis of the situation was that the new company, with its background of experience, goodwill and extensive connections in the main trading centres of Canada and the United States, was bound to succeed, at least in the immediate future, which would have enabled him to sell out at a profit within months. ...

Defendant-petitioner raises an additional argument in connection with this however namely that these expenses were made in 1955 whereas the judgment of the Tax Review Board allowed expenses only during the period in question which ended with the 1954 taxation year. ...

The respondent argued that the profit had resulted from a well- organized and documented endeavour to search for and, if possible, realize a gain upon any items of value to be found in connection with the deep-sea diving pursuit. ...

Subparagraph 110(9)(b)(i), in my view, deals with any form of recompense for expenses in connection with the program, but it is far from certain that this should be extended to also cover an amount treated by an employer as salary or wages. ...

(See Exhibits A-2 to A-6 inclusive, which are photographs of the connection of the pipeline to the plant at Sarnia, Ontario, and of the wellhead structure as well.) ...

In the case of Losey v MNR, [1957] CTC 146; 57 DTC 1098, at page 152 [1101] Thorson, P states as follows: But the value of the goodwill of a business is what a purchaser would be willing to give for the chance of being able to keep the connection of which it consists: vide Austen v Boys (1858), 11 De G & J 626 at 635; Lindley on Partnership, 10th ed, p 523. ...

In the final paragraph Mr Fisher states as follows: It has been established by the Courts in a large number of cases that, where there is any doubt in connection with the application of the provisions of any legislation enacted by parliament, that doubt should redound to the benefit of the taxpayer rather than that of the taxing authority. ...