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Both he and the government appraiser used the cost approach and the market data approach, each giving the sale prices of what they individually considered comparable properties at or about the dates in question, that is 1974 and 1977. ...

Indeed, he considered these allowances as received for expenses incurred by him for board and lodging in respect of, in the course of or by virtue of his employment at the aforesaid work site. 3.16 On June 21, 1977, the respondent issued notices of re-assessment that included the aforesaid allowances in the appellant’s income for the concerned taxation years on the basis that they were allowances for personal or living expenses. 3.17 Following the notice of objection produced on August 9, 1977, the respondent maintains the aforesaid notices of assessment by notification of confirmation dated January 3, 1978. 3.18 An appeal was lodged on February 28, 1978, before the Tax Review Board. 4. ...

This leads me to believe that the question I have raised and which was discussed by counsel and me, was not raised in the Piette appeal, nor was it considered at all. ...

Thus an expense incurred procures a benefit of a certain permanence (lasting at least one year) and is considered a capital expenditure. ...

As mentioned, no reference was made to this in the application but, since it is a possibility, it should be considered. ...

The results obtained by this method were compared with results obtained by analysis of market data from sales of comparable farm properties improved with buildings which were considered to have a significant impact on price. ...

Mr Loewen also stated that all the shares and securities were considered to belong to the company and were recorded as assets of the corporation as security for the company bank loans of $20,040. ...

This was done on the advice of his accountant who considered it “reasonable for tax purposes to charge all his expenses on his Thunderbird as business expense” and his wife, in operating Seagull, made no deductions in her tax return. ...

Although there did exist at one time an employer/employee relationship between the appellant and the employer, whatever hesitation I may have had in concluding that the amount of $6,128.55 received by the appellant after he had been dismissed from office was income from employment, completely disappears when section 3 of the Act is considered in conjunction with subsection 6(3) of the Income Tax Act, 1970-71-72, c 63, as amended. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...