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While each year differed somewhat, of course, the year 1977 is typical: DOROTHY WILD STATEMENT OF INCOME AND EXPENSES JANUARY 1, 1977 TO DECEMBER 31, 1977 FARM INCOME Maple Syrup Sales 790.00 Land Rental 480.00 1,270.00 FARM EXPENSES Property Taxes (Personal 729.95) 1,029.95 Mortgage Interest (Personal 1,069.78) 2,139.56 Syrup Expenses — Wood, Heat 181.00 Repairs 48.28 Syrup Cans 128.00 Pails & Filter 4.31 Horse Ration & Sundry 120.52 Repairs — Equipment 601.32 Building 257.28 Accounting 35.00 Snow Plowing 25.00 Gas & Oil — Tractor & Truck 193.00 Truck Insurance 54.00 Farm Insurance 264.00 Hydro & Heat (Personal 1,040.00) 1,440.00 Capital Cost Allowance 2,710.76 Less Personal Use (2,839.73) 6,392.25 NET FARM LOSS 5,122.25 From the Notice of Objection: Net Loss Allowance 1977 Restricted Farm Loss First 2,500.00 50% of 2,622.25 Balance 1,311.12 Restricted Farm Loss 3,811.12 In making the “adjustments” referred to in the notice of appeal, (supra), the appellant did deduct certain items which she considered “personal”. ...

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

The Court, however, wonders whether such an expense could not be considered as one of the “nothings” stipulated in provision 14 and does not meet the requirement of “eligible capital expenditure” as provided in provision 14(5)(b)(i). ...

It would appear from the evidence that this was not the first time these five gentlemen considered going into a farm venture. ...

That includes the rejection of the assertions made by counsel for the appellants, that one particular amount ($27,790) if considered as income should be credited in the year 1977 rather than the year 1976. ...

One might pick from section 3 just the following: (a) determine the aggregate of amounts each of which is the taxpayer’s income — from a source — and from subsection 4(1) (a) — and was allowed no deduction in computing his income for the taxation year except such deductions as may reasonably be regarded as wholly applicable to that source — and from subsection 4(3) — all deductions allowed in computing the income of a taxpayer for a taxation year — shall be deem to be applicable either wholly or in part to a particular source — [Emphasis added] The appellant did not show that the “farming” operation in question should not be considered a “source”, and therefore the appeal must fail. ...

The applications made on behalf of the applicants, dated October 6, 1982 is allowed and the notices of objection, signed by the applicants and dated October 7, 1982, are considered valid. ...

Both experts considered five sales of nearby properties (“M” designates Mr Markle and “G” designates Mr Grey): As noted previously, this general area (Okanagan Mission) had not been restrictively zoned. ...

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. ...

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. ...