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He also stated that the city made an offer that he considered insufficient and consequently refused it; that the city should have bought his farm because it was cheaper than other lands it acquired. ... Counsel for appellant terminated by saying that the appraiser for the respondent should have used the F & M property as a comparable to appraise the appellant’s farm because the property should not be considered as agricultural but as commercial land for its appraisal on V-Day. ...

Presumably it has not been considered adequate by the Department. A letter of opinion (in accordance with paragraph 4 of the Circular) was not obtained by the taxpayer, but two offers to purchase were filed with the Board. These were not considered acceptable by the Department since they contained conditions required by the interested purchaser. ...

On my 1975 taxes, I submitted what I considered legitimate expenses and they were disallowed. ... A trip from his home to his employer’s work site is not considered to fall within that subsection and, as the Board knows, there are several decisions. ...

The Board considered as being proven in its entirety the following subparagraphs of paragraph 6 of the Reply to the Notice of Appeal: a) the Appellant is a land developer who through companies and partnerships in which he and his brother and their respective wives hold interests has been involved in the business of construction and sale of residential properties; b) the Appellant and his brother David Welton, each have a 50% interest in the following companies; Welton Limited; Welglen Limited; Rivergate Limited; the Appellant was president of Welton Limited; c) Joan Welton, the wife of the Appellant is the beneficial owner of all of the shares of Zebulon Limited; Iva Welton, the wife of the Appellant’s brother, David is the beneficial owner of all of the shares of Roton Limited; Zebulon and Roton have formed a corporate partnership under the name of Zebro Estates which is a land owning company; d) by Deed dated June 14, 1966 the- Appellant through his wife acquired a parcel of land in a subdivision development in Mississauga for $5,000 from Rogerswood Estates a corporate partnership in which the wives of the Appellant and his brother were partners; Welton Limited constructed a house on the property for the Appellant at the cost price to Welton Limited; the Appellant and his wife and family lived there for approximately two years; e) by Deed dated October 24, 1968 and registered November 5, 1968 the Appellant sold this property in an arm’s length transaction for $55,250; the Appellant treated the gain made on the sale as a Capital gain; f) by Deed dated October 29, 1968, the Appellant through his wife acquired from Welton Limited another piece of land in Mississauga on which a house had been constructed by Welton Limited. ... He sold it because 1) it was in the midst of sixty other houses; 2) the neighbours who bought the houses from the company were always asking for something or complaining about the houses; 3) they were considered as second-class citizens and his wife could not stand that anymore. ...

Counsel for the Crown, while not accepting the Bryce decision, said with respect to that decision, it appears that two positions were not submitted to the Board or, if they were, it would appear that they were not considered. ... In addition, the Bryce case does not indicate a consideration of the word “periodic” in section 60.1 in that the payments therein have to be at least “periodic” to be deductible and the type of payment disallowed in the appeal was of the type considered in the Weaver case by the Federal Court of Appeal. ...

Individual resident in Canada during part only of year—Notwithstanding subsection 2(2), where an individual was resident in Canada during part of a taxation year, and during some other part of the year was not resident in Canada, was not employed in Canada and was not carrying on business in Canada, for the purpose of this Part, his taxable income for the taxation year is the aggregate of (a) his income for the period or periods in the year during which he was resident in Canada, was employed in Canada or was carrying on business in Canada, computed as though (i) such period or periods were the whole taxation year, (ii) any disposition of property deemed by subsection 48(1) to have been made by virtue of the taxpayer's having ceased to be resident in Canada were made in such period or periods, and (iii) any amount deemed by subsection 48(1.1) to be a capital gain or capital loss for the year from an indexed security investment plan were a capital gain or capital loss, as the case may be, for such period or periods, and (b) the amount that would be his taxable income earned in Canada for the year if at no time in the year he had been resident in Canada, computed as though the portion of the year that is not in the period or periods referred to in paragraph (a) were the whole taxation year, minus the aggregate of such of the deductions permitted for the purpose of computing taxable income as may reasonably be considered wholly applicable to the period or periods referred to in paragraph (a) and of such part of any other of those deductions as may reasonably be considered applicable to such period or periods. ...

So far as I am aware, it has not been judicially considered heretofore. ... It may well be that Parliament, in enacting Section 11A, considered that all successions under the Dominion Act would also be subject to duty under a Provincial Succession Duty Act, and therefore made no provision for cases, such as the instant one, in which a substantial part of a number of successions paid no provincial duty. ...

The CRA’s notes [Notes] dated June 20, 2023 clarify, that the Applicant was forgiven for the CERB benefits; and for the purpose of preventing a redetermination, the Applicant was considered “eligible.” ... Conclusion [28] The record demonstrates that the Officer considered the documents submitted as well as the explanations provided during the numerous interactions with the Applicant. ...

However, that is here purely an academic question and the point need not be considered as it was not raised at the trial. ... If the regulation is valid, and for the purpose of this case it is so to be considered, then it seems to me quite clear that it was intended that the regulation was to apply to the suppliant in precisely the same manner as it was to other dressers and dyers of furs. ...

The appellant having requested the County Judge on the hearing of the said appeal to make a note of the questions of law to be considered and to state them in the form of a special case for a Divisional Court pursuant to the provisions of sec. 84 of the Assessment Act, the facts above set forth were so stated for the consideration of a higher court. ... The House of Lords then considered the matter and the judgment of the House was read by Viscount Dunedin, pp. 460-465, and while it said that ‘‘after all, the question is an individual one as to each particular hereditament’’, the appeal was determined upon the proper construction to be put upon the words of the statute. ...