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The significant fact in this connection is that knowledge of the ‘comparable’ sales on which the experts based their opinions in this case appears to have been, without any significant exception, obtained from copies of conveyances of agreements with no accompanying information as to the surrounding circumstances or the purposes for which the properties were acquired. ...

It is my understanding that Mr Elliot had been retained by Shell Oil in connection with the sale of the service station and was asked to determine the market value of both properties based on their highest and best use. ...

The matter of ties within the jurisdiction asserting residence and elsewhere runs the gamut of an individual’s connections and commitments: property and investment, employment, family, business, cultural and social are examples, again not purporting to be exhaustive. ...

The respondent also cited the Williams Brothers Canada Ltd decision in this connection. ...

He stated that, subsequent to August 13, 1976, but before the end of that year, in connection with some other matter he attended his solicitor’s office. ...

Accordingly (and I would think there should be little argument about this), any relief available to this taxpayer from the Board must arise from the provisions of paragraph 8(1)(f) of the Act which, as it is relevant to this appeal, reads: Deductions allowed (1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (f) Salesman’s expenses—where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was Ordinarily required to carry on the duties of his employment away from his employer’s place of business, amounts expended by him in the year for the purpose of earning the income from the employment (nor exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year).... ...

In that case, the Minister of National Revenue proposed just such a constructive trust in connection with real property in order to tax an individual whose name never appeared on the legal title to the property. ...

._.. it is clear that from the start the group intended that Mr Roher would provide not only the development expertise, but also the connections with the financing, and subsequently when he disappeared into the blue, the group anticipated that Mr Dorosh would perform the same function, and I think felt that if the land were decently situated and properly serviced, as it appeared to have every possibility of being at the time they bought it, that it would not be very difficult at all to attract a developer who would then assist in developing and finding someone to do the financing. ...

R3C 0P5 Gentlemen: Re: Mr Aubie Jacob, 91 Verbena Street, Winnipeg, Man R2Y 3A6 SI N 603 589 210 I have been asked by the above named taxpayer to write to you in connection with the T-4 slip which I prepared as receiver and manager of PR Creations Unlimited Limited showing his remuneration and applicable deductions for the 1975 taxation year. ...

I formed the view as he gave his evidence that he was inclined to treat his rental costs, outlays which cannot realistically be said to have had any connection with the income earning process. ...