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With respect to the argument in connection with the TOM 11 for CRA investigations, the Judge rightly noted that the TOM 11 “is a set of guidelines that have no binding legal effect and their breach is not evidence per se of a wrongful prosecution or negligence” (Judge’s decision at para. 168). ...

I cannot distinguish it from other structures to be found on a farm such as silos, green houses and barns, any of which have machinery or implements installed in them or used in connection with them. ...

The extent of the appellant’s revenue from his real estate activities appears from the following figures: 1959 — Commissions $36,436.28 — Profits nil 1960 — Commissions $ 9,000.00 — Profits $80,647.98 1961 — Commissions $32,722.08 — Profits $30,500.00 1962 — Commissions $37,349.32 — Profits nil No problem has arisen in connection with the appellant’s revenues from his real estate activities. ...

It is of some significance to note in this connection that the lands were entered in the books of the company in an account under the heading ‘‘ Land for Resale’’. ...

He had to sell off these cattle at short notice to pay the bank and, although there was some profit made in connection with the basic herd, it was a capital gain. ...

R. 621, as follows: To determine whether a person has ceased to be resident of any particular place, the duration of his previous residence, his connections with that community and his interest in it are circumstances to be considered. 13 As to the application of Article 10 of the Canada-France Income Tax Convention, I note that Article 2, paragraph VI, defines the term “permanent establishment” in a manner which, in my humble opinion, places a limitation on Article 10, if in fact Article 10 applies in the instant case. 14 In answer to a direct question on cross-examination, the appellant stated that he paid no income tax in France. ...

When land has been purchased at a tax sale, the legally registered owner has a period of 12 months in which to repay the taxes plus, I think the evidence was, interest or some other terminology, at 10 per cent to make up for the prospective purchaser having had his money tied up for that period of time. 6 It is clear that Doral, at the time it made this substantial advance to East End in January 1968, had, according to the evidence that has been adduced, every reason to believe that a substantial and large income- producing future lay ahead as a result of its connection with East End. ...

In a letter of October 29, 1971 (Exhibit A-8) A & W's solicitors, on the assumption that Richfield Real Estate Ltd and Mr Brad Calvin, who had been acting on behalf of A & W had business interests with the appellant company, and particularly in connection with the proposed sale with Trojan, stated that A & W was no longer prepared to grant possession of the McLeod property unless a statutory declaration was signed by Messrs Calvin and Kitzul that no such business interests existed between them. ...

The evidence also shows that the appellant was not allowed to practise ophthalmology other than in connection with his teaching at the clinic. ...

Section 2: To control and operate Minor Hockey within the District of Quesnel; Section 3: To promote and inform the members of the Mutual Aid Fund, as a means of assistance to members injured in play, in authorized Hockey activities, to ensure the best possible safety standards are set and maintained by the Association. 7 After expenses, including referees' and linesmen's pay, the concession netted the following seasonal income: 1990-1 $ 3,070.27 1991-2 19,312.51 1992-3 5,573.29 1993-4 1,055.53 The concession posted advertisements for tournament breakfasts with which it had no connection. ...