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According to the evidence adduced, there is no way that the activities of the taxpayer can be considered as a business before his election as councillor. ...

He also wanted liquidity and had considered the possibility of making the taxpayer a public company. ...

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being—Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business ip carrying out a scheme for profit-making? ...

The general pattern of Jacob and Max Borinsky in acquiring properties and retaining them for income purposes is also a factor to be considered. ...

As late as May 13, 1974 a letter from the commissioner, J JG Gaudaur to Mr R J Sazio, president of the Football Club points out that these transfers as well as what he refers to as the proposed transfer of 5,100 shares from Mr DeGroote to Pine Hollow Holdings Limited must be approved by the commissioner or executive committee before the transfer can be considered effective. ...

The plaintiff is a company which was incorporated pursuant to the laws of Saskatchewan, on February 6, 1959, having the following restricted objects: (a) To acquire land and any other property in the South-Eastern Section of the City of Regina, in the Province of Saskatchewan, or elsewhere in the City of Regina, for the purpose of Community Shopping Centre or Centres; (b) To develop a community shopping centre or centres in the City of Regina and for that purpose to construct, build, improve, lease, rent, control, develop and manage all and every kind of building, structure, shop, store, office, premises, plant, service station and any other business or other premises of all or any kind which may be considered conclusive or incidental to the development or benefit of any such shopping centre. ...

Whether this has had any effect on the general question of residence will be considered later. ...

It would be difficult to speak of a complete transfer in this case, when it is noted that Péloquin undertook to continue serving his clients, if asked, that he became at least nominally a member of the firm, that he specified that the services to his clients would be provided in his name, and especially that he reserved the right for two years to terminate the agreement at will and resume complete control of his practice, if he considered it advisable to do so. ...

It is the nature of income taxation that taxpayers must disclose all manner of financial information which in other circumstances might be considered highly personal and private. ...

(Pages 21 & 22, Transcript) In relation to what happened with the family allowance cheques received during the marriage, Sadavoy related that he considered the cheques payable to both parents, were deposited to his bank account or to a joint bank account, I assume "joint" being he and his wife, and that it (the cheques) was something that he counted on. ...