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Duff 983367 Attention:XXXXXXXXXX March 1, 1999 Dear XXXXXXXXXX: Re: Farm Land as Qualified Farm Property This is in reply to your letter of December 11, 1998, requesting our views as to whether farm land, described in various situations, would be considered to be qualified farm property for the purposes of subsection 110.6(2) and whether it can be rolled pursuant to subsections 70(9) and 73(3) of the Income Tax Act. ...

To the best of your knowledge and that of XXXXXXXXXX, none of the issues discussed in this letter are being considered by a tax services office or taxation centre in connection with a tax return already filed nor are any of these issues presently under objection. ...

Additional Information To the best of your knowledge and the knowledge of XXXXXXXXXX, none of the issues involved in this ruling request is being considered by a tax services office or taxation centre in connection with an income tax return already filed, and none of the issues is under objection or appeal. ...

(a)To the best of your knowledge and that of the members of the XXXXXXXXXX Group none of the issues involved in your ruling request is being considered by a tax services office or taxation centre in connection with a tax return already filed and none is under objection or appeal. ...

In considering the application of subsection 4(4) "double taxation" is frequently considered to occur where a deduction was not taken that would normally offset an income inclusion as occurred in the Langille case. ...

Other Information To the best of the Employers' knowledge, none of the issues involved in the requested rulings is being considered by an office of Revenue Canada in connection with a tax return already filed, and none of such issues is the subject of any notice of objection or is under appeal. ...

To the best of your knowledge, and that of the parties to this ruling, none of the issues contained in this advance income tax ruling is being considered by a Tax Services Office and/or Taxation Centre in connection with an income tax return previously filed and none of the issues contained herein is under objection or appeal. ...

To the best of your knowledge and that of the taxpayers involved: (i) none of the issues involved in the requested ruling is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed; and (ii) none of the issues involved in the requested ruling is the subject of any notice of objection or is under appeal. ...

ADDITIONAL INFORMATION You advise that to the best of your knowledge, none of the issues involved in the ruling request is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed and none of the issues is under objection or appeal. ...

Le juge Noël a fait les commentaires suivants concernant les dépenses réclamées par le contribuable: I do not believe that, as submitted by counsel for the Crown, because the expenses paid by Pigott could, in the event the project was successful, have been paid by First Wentworth upon being billed by Pigott and then could have been considered by First Wentworth as capital expenses and recoverable as capital cost allowances under the Act, should render the expenses non-deductible to Pigott. ...