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The attached statement of liabilities (Appendix "A”), showed: Unsecured $17,507.00 Secured 3,000.00 Preferred 28,000.00 Total $48,507.00 The $3,000 "secured” liability above was the chattel mortgage on the automobile shown as an asset above; the $28,000 "preferred” liability was really a "contingent liability” in connection with his personal guarantee, (together with other shareholders) on a mortgage held by the Canadian Imperial Bank of Commerce on the hotel property of 429011 Ontario Ltd. ...

There does not appear to be any mathematical connection between that amount and any of the other clauses in the Agreement. ...

. — The Respondent further submitted that the deduction by the Appellant of the rental expenses incurred by it in connection with leasing additional space directly across the street from John Mor Corp. ...

Such a computation is not made where, as here, the land in question was not used or held in connection with the generation of income, whether from business or from the property itself. ...

I do not read the case to be authority for a proposition that “capital amounts" are not deductible — as I read it, the reason for disallowance must have been because costs in connection with the "acquisition of his new residence" (subsection 62(3)) are restricted to such items as legal fee, transfer and registration — (paragraph 62(3)(f)). ...

We are requesting your Federation's immediate written confirmation that no such receipts will be issued in this connection. ...

The word “combination" in subsection 31(1) does not require any connection by way of physical relationship or integration or interconnection between farming and the activity which provides another source of income. ...

For the Minister the situation was stated as: — the Appellant had no experience or training in horse racing; — the Appellant was capable of investing further capital in the operation in order to demonstrate his commitment but chose not to; — the Appellant failed to identify the inherent risks in horse racing prior to the purchase of “Clacton Cannon”; — the Appellant did not pursue a plan for management of the risks or minimization of the risks; — there was no profit in the years 1980 and 1981; — the Appellant was operating a hobby farm; — the hobby farming activity was maintained by the Appellant for his own use and benefit and was not maintained in connection with a business carried on for profit or with a reasonable expectation of profit; — the expenses incurred by the Appellant were personal or living expenses and not outlays or expenses incurred to earn income from a business or property. ...

It was alleged that the second parcel of Pt 199 had been purchased with Harry Palnick so that the latter could use this land, if necessary, in connection with his own land which he was working, not far from Pt 199. ...

They read as follows: SEC 31 (1) Where a taxpayer’s chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deductions under section 37 or 37.1, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) /2 of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500 and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words “and before making any deduction under section 37 or 37.1” were deleted, SEC 248 “Farming” — “farming” includes tillage of the soil, livestock raising or exhibiting, maintaining of horses for racing, raising of poultry, fur farming, dairy farming, fruit growing and the keeping of bees, but does not include an office or employment under a person engaged in the business of farming; “Personal or living expenses” — “personal or living expenses” includes (a) 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 reasonable expectation of profit, 4.02 Case law The parties referred the Court to the following cases: 1. ...