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It has not been shown by the respondent that /f the leased automobiles in this appeal were originally acquired for sale (and that is the proposition of the appellant), a conversion decision was made by Plaza after such acquisition to use certain of them in a separate business, or a distinct part of the total business — the leasing of automobiles, in such a way that they should be considered as capital rather than inventory assets. ...

The parties agreed that the appeal be considered on the record and transcript of the evidence and argument by another member. ...

It is also the same for “Gambling Lions Club” (para 3.10.9), “Gene DVA Loans” (para 3.10.19) and “Insurance Policy” (para 3.10.21) etc. 4.03.3 On another aspect, even if the point “Laberge” $15,000 (para 3.10.14) is true, it cannot be considered in the present case because part of the amount was declared in each of the 1977 and 1978 income tax returns. ...

The Department has then considered the effective date the actual date of reception of the said assessments. 3.10 Concerning the reassessments issued in August, 1980, Mr Wexelman testified that Mr Klein called and asked him: If there was any assessment ever received by me. ...

The new broker considered this delicacy of “the paternalistic Canada Life” towards the appellant as a kind of obstacle to complete a transaction with Canada Life. ...

Findings “Inventory” is defined as follows in section 248 of the Act: “inventory” means a description of property the cost or value of which is relevant in computing a taxpayer’s income from a business for a taxation year; The relevant section to be considered by me is paragraph 20(1)(gg) of the Act which reads as follows: 20. (1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amount as may reasonably be regarded as applicable thereto: (gg) an amount in respect of any business carried on by the taxpayer in the year, equal to that portion of 3% of the cost amount to the taxpayer, at the commencment of the year, of the tangible property (other than real property or an interest therein) that was (i) described in the taxpayer’s inventory in respect of the business, and (ii) held by him for sale or for the purposes of being processed, fabricated, manufactured, incorporated into, attached to, or otherwise converted into or used in the packaging of, property for sale in the ordinary course of the business that the number of days in the year is of 365; (Italics mine). ...

Who can tell the Board whether, of the five sales considered by the respondent, the vendors had taken the trouble to have their property valued by expert appraisers? ...

Therefore, even though the parties in this proceeding jointly filed a notice of motion, the Court must nevertheless analyze everything in exercising its discretion to give a final determination as to whether the application should be allowed or dismissed. [30] Secondly, although the parties did not cite Rule 4 of the TCC Rules, I am of the view that it must be considered, since it provides that "[t]hese rules shall be liberally construed to secure the just, most expeditious and least expensive determination of every proceeding on its merits. ...

The latter considered that these sums were advances or loans to the company. ...

That was a point of view considered to be serious in Rawsthorne the three sworn testimony accounts already varied widely. ...