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—all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (vii) allowances (not in excess of reasonable amounts) for travelling expenses received by an employee (other than an employee employed in connection with the selling of property or negotiating of contracts for his employer) from his employer if they were computed by reference to time actually spent by the employee travelling away from The appellant submitted that the amount of $1,500 received as travel expenses (mileage and rest expenses) was reasonable and that he had to travel outside the municipality where the employer’s establishment was situated. ...

(B) is paid in connection with... the rendering of services for his employer or a foreign affiliate of his employer. ...

He concluded by stating that the Comité paritaire de l’industrie de l’automobile de Montréal et du district (hereinafter referred to as the “parity committee’’) is not the employer of the employees nor the representative of the employer; that the employees have not performed any duties and functions for the parity committee; and that section 153 and the Regulations envisage a close connection between the person paying the remuneration and the person for whom the employee performs his duties and functions. ...

The item was also intended to reflect the cost of feeding and stabling horses which were used in part for pleasure and in part in connection with the cattle-raising operation. ...

. — In the further alternative, the appellant is entitled to the deductions permitted by division C in connection with the said rental property in the computation of the appellant’s taxable income. ...

It was apparent in October of 1973, when Mrs Schiel resigned and severed her connection with Oldco pursuant to the agreement, that one of the joint ventures would be quite profitable. ...

—all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except (v) reasonable allowances for travelling expenses received by an employee from his employer in respect of a period when he was employed in connection with the selling of property or negotiating of contracts for his employer. 8(1)(h) Travelling expenses. ...

Paragraph 66(15)(c) reads: In this section and sections 66.1 and 66.2, (c) “Canadian resource property” of a taxpayer means any property acquired by him after 1971 that is, (i) any right, license or privilege to explore for, drill for, or take petroleum, natural gas or other related hydrocarbons in Canada, *(ii) any right, licence or privilege to prospect, explore, drill, or mine for, minerals in a mineral resource in Canada, (iii) any oil or gas well situated in Canada, (iv) any rental or royalty computed by reference to the amount or value of production from an oil or gas well, or a mineral resource, situated in Canada, (v) any real property situated in Canada the principal value of which depends upon its mineral resource content (but not including any depreciable property situated on the surface of the property or used or to be used in connection with the extraction or removal of minerals therefrom), or *(vi) any right to or interest in any property (other than property of a trust) described in any of subparagraphs (i) to (v) (including a right to receive proceeds of disposition in respect of a disposition thereof); (*asterisks mine) Counsel for the respondent referred to the wording of paragraph 9 of the 1956 agreement and suggested that, notwithstanding that his interest was subject to various conditions, the appellant received a right to a 7% undivided interest in each discovery area as well as a right to a 7% portion of the proceeds if the company sold before the expiration of 21 years. ...

I fail to see therefore that the appellant has bridged the gap between the gratuitous award of a retirement allowance from Holdings, and the possible claim for damages in connection with the termination of the employment contract of the appellant. ...

These circumstances, which I believe were “exceptional and unusual” in Garneau (supra) and not to be found in this matter, are: (1) there was no indication either at the time of Garneau’s original involvement with the group or at the time of the investment at issue in that appeal that the business itself was in difficulty. (2) the turn of events requiring the investment resulted from a policy decision at the senior ownership and management level, simply the withdrawal of the main base of capital support, not supplied by Garneau. (3) there was to be formed a “new company” which would carry with it “its background of experience, goodwill and extensive connections in the main trading centres”, (pp 291 and 5192 respectively) (4) the investment was one time and one time only—not several different stock acquisitions under differing circumstances and over a period of time. (5) his analysis of the business at the time of his investment showed good prospects for capital stock value improvement—at least in the short term. (6) there is no indication that any efforts were proceeding within the group to sell, merge or amalgamate the operation with another stock broker. ...