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The respondent allowed the deduction of expenditures made in connection with this horse for each taxation year, in addition to the purchase price for the 1960 taxation year, for a total amount of $36,100. ...

From a consideration of all the facts which have been disclosed in the evidence adduced at the hearing, I have reached the conclusion that the liability assumed in connection with Vaillancourt Inc’s line of credit, and which the appellant was called upon to pay, was nothing other than an outlay of capital made by it on behalf of P P Vaillancourt Inc, no doubt with the hope of preserving what had in the past proved to be, for the appellant, a valuable source of lumber at an advantageous price. ...

He has had no connection since then with the Marquis company, either as a shareholder or as a director. ...

Minister of National Revenue, [1972] CTC 2528, 72 DTC 1438 A J Frost:—This is an income tax appeal in respect of the appellant’s 1962 taxation year wherein an additional tax to the extent of $17,146.75 was levied in connection with the profit realized from the sale of the appellant’s partnership interest in O H Ranch. ...

Legal expenses in connection with the transaction amounted to $800. 3 It was adduced in evidence that the shares of Chapels Limited were purchased in order to make it possible for the appellant company to earn income from its management business rather than dividends from an investment, and that subsequent to the purchase, a management agreement was in fact drawn up clearly indicating that the intention of the appellant was to earn only taxable income. 4 Mr G J Forest, CA, who represented the appellant, in the early stages of the hearing agreed with the position of the Minister with respect to life insurance costs of $452.47. ...

I know of no case that holds that buying raw land as an investment and later disposing of it at a profit makes it subject to income tax per se, and in this connection I would like to express my appreciation to both counsel for leaving with me for perusal the various cases to which they made reference in the course of their respective submissions. 13 The uncontradicted evidence is that the appellant started out with but one intention, to invest in land as the safest form of investment having regard to his background. ...

If one looks through the agreement, one sees that what is in effect to happen is that, at the end of the agreement, the vehicles or substitute vehicles are to be returned in approximately the same state in which they were received in 1963. 6 Throughout the agreements the inference is that Prompt was in fact the owner of the motor vehicles but all the expenses in connection with the operation including insurance liabilities, etc were to be paid by the manager as part of his management agreement. 7 If one goes to appellant's Exhibit 4, which was drawn up in 1971 as an addition to Exhibit A-3, one finds that, notwithstanding anything contained in the agreement of September 30, 1971 (Exhibit A-3) (which was the second agreement entered into), it is specifically agreed that, upon the termination of said agreement or any renewal thereof, the manager shall have the absolute right and option to acquire ownership of the 60 taxi automobiles by paying to Prompt the sum of $18,000, which was the equity that Prompt had in the vehicles turned over to Vininsky at the time the original contract was entered into. 8 I could mention several other terms of the agreements that lead me to the same conclusion but, on all the evidence, I cannot come to the conclusion that the appellant has discharged the onus cast upon it by the Act and the appeal must be dismissed. ...

Mr MacFarlane does most of the work in connection with the buildings from his law office, but when he is required, as he says he is, to attend at the building to see whether the cleaning and general upkeep of the building is done, he does so in the evening. ...

The appellant’s protestations that the additional expense which he incurred at the time in connection with the subdivision was a most unwelcome burden to his small business are believable, and appear to be consistent with his evidence that his purpose in any efforts at disposal was only to reduce his net capital investment. ...

The appellant corporation, through its director and secretarytreasurer, C Miller, Esq, QC, who testified on its behalf, commenced negotiations in this connection. ...