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They then went to see a lawyer for the purpose of having a document drawn up in connection with the formation of a syndicate. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...

In the Irwin appeal, the Minister has filed a consent to judgment with the Board allowing the appeal with respect to the appellant’s 1965 taxation year and also with respect to two of the three issues raised in his 1966 taxation year, the remaining issue still to be disposed of being the one involving the taxability of Irwin’s 1/3 share of the profit of $24,398 allegedly made by him and the said McDonald and Vincent equally in connection with the sale on September 28, 1966 of their joint interest in Claim Block CBS 355 consisting of 7,200 acres, more or less, situated in the Athabasca Mining Division in the Province of Saskatchewan, which is shown on Claim Map 74-10-SW in their respective 1966 taxation years, the division of the said profit of $24,398 being as follows: McDonald $8,132.67 Vincent 8,132.67 Irwin 8,132.66 Total as above $24,398.00 The parties were represented by counsel as follows: F D Jones, Esq for the three appellants mentioned above and T E Jackson, Esq for the Minister. ...

The following quotation taken from the Board’s reasons for judgment in the Consolidated Mogul case (37 Tax ABC 363 at 380) — the part thereof marked off by quotation marks having been later quoted with approval by Mr Justice Spence of the Supreme Court of Canada — appears to be singularly applicable and helpful to First Roman, Trans-Canada and Second Roman in this appeal in connection with their 1962, 1964 and 1965 taxation years, respectively: While these comments are based on my own personal observations, I think it is perfectly correct to say that one very important phase of the mining business is the extensive network of connecting links which exists between the various mining companies making up the industry in the form of: option agreements, escrow agreements, voting trust agreements, pooling agreements, agreements for services, assignments and management contracts, to name only a few of the many types of arrangements which are regularly entered into between mining companies. ...

In Halley v MNR, [1963] Ex CR 372; [1963] CTC 108: 63 DTC 1090 Thurlow, J said at page 375 [111, 1092]: In my opinion the word “absolute” even when used in a technical sense in connection with the vesting of property may signify at least two different legal concepts. ...

The appellant has cited the case of Lumbers v Fretz, 62 OLR 635; (1928), 63 OLR 190; [1928] 4 DLR 269, in this connection. ...

The expenses related primarily to interest and taxes on property and these are annual, recurrent expenses in connection with the holding of property acquired to earn income. 4, It is not necessary to trace any expense to a particular item of income, the whole as was established years ago in the judgment in Consolidated Textiles and the Minister of National Revenue. 5. ...

He had to sell off these cattle at short notice to pay the bank and, although there was some profit made in connection with the basic herd, it was a capital gain. ...

R. 621, as follows: To determine whether a person has ceased to be resident of any particular place, the duration of his previous residence, his connections with that community and his interest in it are circumstances to be considered. 13 As to the application of Article 10 of the Canada-France Income Tax Convention, I note that Article 2, paragraph VI, defines the term “permanent establishment” in a manner which, in my humble opinion, places a limitation on Article 10, if in fact Article 10 applies in the instant case. 14 In answer to a direct question on cross-examination, the appellant stated that he paid no income tax in France. ...