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If it is arbitrary (and therefore wrong) to reduce the amount of interest deductible because the property was 100% financed, it would be equally arbitrary to pick a number of years (say three or five) in which the appellants must start earning a profit. 28 Here the appellants started earning a profit in eight years and have a plan to pay off the mortgage within a reasonable period of time. 29 I find as a fact that the appellants have demonstrated that, contrary to the four bases of disallowance set forth in the assumptions, they had a reasonable expectation of profit, that the expenses in connection with this rental project were laid out for the purpose of gaining or producing income, that they were not personal or living expenses and that they were not unreasonable. 30 In fact the last point, that the expenses were unreasonable, was abandoned at trial. ...

No. 30, amended version (the Convention). [4] The appellant is a trustee of Canadian Trusts that have been the subject of 14 requests for information made by France in connection with audits of its tax services involving 11 French residents. ...

However, the fact that they had money so available was obviously known to the solicitors who approached them and who did all legal work in connection with the transactions. ...

A parish priest and a separate school inspector approached the appellant, as a responsible and interested member of the community and latterly an alderman for the area, with the suggestion that it would be expedient to acquire land upon which to build a bilingual separate school in connection with the new church. ...

Lechter may, so he testified, have entered upon this deal on his own, without any company affiliation or partnership connections, and, nonetheless, have pursued a profit making scheme which the law renders liable to income taxation. ...

While the admission that the profit from the appellant’s transactions in connection with the Zultak farm was income suggests that the appellant had corporate power to trade in land, in the absence of documentary proof of the objects of the incorporation, which the respondent as well as the appellant might have offered if he regarded it as advisable to do so, I would infer from the fact that the appellant prior to the purchase had been engaged for many years in an operation consisting only of brickmaking that dealing in real estate was not one of the objects for which the appellant was incorporated. ...

Lily Wurtele, ‘‘... during the lifetime of the parties and so long as the plaintiff shall live separate and apart from the Defendant... ” (exhibit 1, para. 4), was delayed until September 16, 1932, when the Local Master of the Court, after stipulating a monthly payment of $600 to the wife, purported to draw up a settlement deal ‘‘... in connection with the existing insurance policies upon the life of the Defendant... ” (ef. exhibit 2, paras. 3 and 4.) ...

In making the assessments the Minister disallowed as a deduction in computing income a loss of $591,495.75 admittedly sustained by the appellant in 1957 in connection with his shareholdings of Eastern Steel Products Limited and the first and main question which arises in the appeal is whether the Minister was right in so doing. ...

On this score, my opinion is strengthened by the schedule suggested in connection with the Burrard Street sale and accepted by both parties. ...

In this connection it is important to consider the facts. They are set out in detail in the agreed admission of facts to which I have referred but a summary of them will be sufficient. ...