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Part of this letter reads as follows: As executor, his duties amongst others consisted of: a) determining the names and addresses of those persons beneficially entitled to the estate and notifying them of their interest; b) determining the full nature and value of the assets of the deceased and compiling a list of them; banking, (deposits and making cheques) c) employing an accountant to advise in the administration of the estate and assisting wherever necessary; (investment of Estate assets) d) determining the debts owing to and by deceased and arranging for payment of them; e) contesting/settling debts, if any are in doubt; f) determining the income tax liability of the deceased; and of the estate; paying any tax owing; obtaining an income tax clearance in respect of the estate in compliance with income tax law; g) distributing assets of the estate “in specie”, as the will directs, or, alternatively, if there is discretion, to convert into money and distribute them among those beneficially entitled thereto; h) accounting to the beneficiaries, and the court, if required to do so, for all actions in connection with the administration of the estate; He charged the Estate $12,500 as compensation for his services based upon the amount of time which he spent on Estate business; during this period, the Estate had $24,943 of taxable revenue. ...

During the period from 1973 to 1985 the precise role and functions of Marlowe-Yeoman and Gulf Investments and the relationship between these two entities in connection with the operations of the G.M.S. are not easy to determine. ...

Simon's Income Tax 1964-65, Vol. 1, has this to say at page 59 in connection with the case of C./.R. v. ...

There need not be any connection between farming and the 'other source of income’ for a taxpayer's chief source of income to be a combination of the two sources, however, the meaning of ‘combination’ in section 31 does not mean the simple addition of any two sources of income for any taxpayer (Moldowan, op cit, page 314; D.T.C.5216). ...

Sykes in connection with the meetings. Certainly Mr. Sykes did not do all the entertaining. ...

In the Spofforth and Prince case (supra), a firm of chartered accountants claimed in the computation of its profits the deduction of certain legal expenses paid in connection with the successful defence of one of the partners who had been charged with conspiracy to defraud the Revenue. ...

That stands in considerable contrast with, as we have here, an obligation to remove all merchantable timber at an aggregate gross specified price within a short specified time in connection with and for the purpose of enhancing the efficiency of farm land use. ...

There need not be any connection between farming and the 'other source of income” for a taxpayer's chief source of income to be a combination of the two sources; however, the meaning of “combination” in section 31 does not mean the simple addition of any two sources of income for any taxpayer (Moldowan, op cit, page 5216). ...

It may be noted at once, in connection with this overvaluation, that the defendant cannot rely on that here as it never made use of the provisions of section 46 of the Customs Act to request a new ruling or valuation; furthermore, what it allegedly overpaid is not the subject of a separate claim or of a counterclaim. ...

In order that the proceeds arising out of a liability under any such contract should become taxable under section 6(1)(a) of the Act, a connection thereto must be found, as I see it, with the contract of employment. ...