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This benefit is tax free by virtue of paragraph 5(1)(a) (old) of the Act as read in connection with paragraph 6(1)(db) (old) to the extent of the first $25,000 of the said amount. ...

There is a document on file to the effect that a commission of $1,000 was paid by appellant in connection with the sale of the property to Mr Gauthier. ...

Dear Sir: Your income tax returns for the 1968 and 1969 taxation years are presently under review and in connection therewith the provisions of Section 13 of the Income Tax Act, as set out hereunder, are brought to your attention. ...

In assessing the appellant, the Minister of National Revenue started from the premise that the appellant had received this $7,000 and then proceeded to make allowance for the disbursements totalling $2,246.54 which the appellant appeared to have made in connection with the execution of the said agreements. ...

Another explanation was given in connection with that purchase. The appellant apparently demanded that Continental repay the $142,500 and asked it for a loan of $269,500. ...

The taxpayer has paid the additional tax applicable, together with interest, and this appeal deals strictly with the penalty assessed in connection with the omissions of income for each of the years in question. ...

Then in 1971 he also acquired the Tradewind Edgewater Motor Hotel, and my recollection is that he paid $75,000 for it with $10,000 down, but it did not prove to be a successful operation and it too was sold. 6 I should say that, in all these transactions, the only evidence of a loss was in connection with the sale of the Quadra Motel, I believe it was, where he lost some $130, approximately. 7 The appellant has given evidence, has stated under oath, that his sole intention was to build the Empire Motel and the Townley Apartments for long-term investment, and that, in effect, his intention was frustrated by the fact that the Empire was too small and he was unable to purchase the land next door because it was part of an estate in which all the beneficiaries were not amenable to selling. 8 It is urged upon me by counsel for the appellant that I should accept this evidence of intention because the Crown has not seen fit to adduce any evidence to refute the intention alleged by the appellant and the appellant is supported by two character witnesses who have given evidence to the effect that he is a man of integrity and one to be believed. 9 In all these cases, it is very difficult to know what the intention is, because one cannot get into the mind of the witness and one must apply his evidence to the facts that are adduced before the Board in order to determine if there is some extraneous corroboration for the alleged intent. 10 There is no question in my mind that a witness such as this appellant is telling the truth as he sees it, and there is no attempt by the appellants in any of these cases, really, to try to mislead the Board or the Court. ...

I do not believe that the degree or the extent of the taxpayer's activity in connection with the normal operation and maintenance of a long-term rental property can automatically transform the taxpayer's investment in such property into an investment in a business. ...

Their analysis of the situation was that the newly formed company with its background of experience, goodwill and extensive connections in the main trading centres of Canada and the United States was bound to succeed at least in the immediate future. ...

The remuneration received from the State University of New York in 1971 was $2,587.34. 17 It is on record that the appellant spent from September 1970 to January 14, 1971 at the State University at Plattsburgh, New York, but continued to work as editor of its “Papers on the Social Sciences” for several months after January 14, 1971, and had to do some travelling in connection with that publication. 18 It seems to me that the appellant's consulting and research activities go well beyond his consultant assignment at New York State University. ...