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The appellants’ rights and liabilities, in my opinion, stem only from the agreement, and the only reference to or connection with the Act is the matter of establishing the quantum of consideration by the respondent. ...

In that connection I would like to refer you to Harris v M.N.R., [1966] Canada Tax Cases, a Supreme Court of Canada decision. ...

That may be; but I think it is also a sound principle under the Income Tax Act that the Minister has applied the formula that he did in view of the fact that moneys were paid in the year prior to that in connection with this same loan, and there was nothing to indicate that it would not be recovered in the future. ...

In 1962 appellant, which regards itself as a manufacturing and processing corporation, and whose sales of goods processed and manufactured in Canada amounted to at least 50% of its gross annual income, took advantage of the provisions of section 40A of the Act which relate to production incentives, complied with the formalities required by the Act in this connection, and was in fact recognized by the Department as being entitled to the said deduction. ...

The words of paragraph 5(1)(a) in this connection are so Clear that it is not necessary to refer to any jurisprudence concerning the interpretation of its provisions. ...

The relevant portion thereof reads as follows: 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. ...

They then went to see a lawyer for the purpose of having a document drawn up in connection with the formation of a syndicate. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...