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The appellant, Yarmon and Tankoos considered the possibility of acquiring this land and erecting thereon a multistorey parking garage with shops on the ground level as that appeared to be the best use of that property for their purpose. ...

I am also satisfied that in the light of the appellant company’s volume of business the expenditure of $8,000 can be considered as reasonable. ...

The application of the pertinent sections of the Act is considered by the appellant as giving rise to an anomalous and unfair treatment of his efforts to comply with his moral responsibilities toward his nephews. ...

However, the broad question arises: Did the appellants go to such extremes in arranging their affairs that they caused dividends to be paid to their wives which, pursuant to subsection 56(2) of the Income Tax Act, must be considered as taxable to the appellants as if they themselves had received the dividends? ...

Argument The appellant presented no argument, merely referring the Board again to the regulation he considered applicable, and to the logic of his proposition. ...

Consequently, the money the appellant company lost by buying shares in and lending money to Eldridge Development Corporation can in no way whatsoever be considered a trading loss because these disbursements had nothing to do with the appellant company’s business. ...

In my view, the possibility of an appeal does not affect the nature of the amount in question as a receivable or its character as income, and under no circumstances can it be considered as transferring the item from one taxation year to the next, or postponing the date when the moneys become receivable. ...

Mr Sabourin placed great emphasis on the highest and best use concept of future industrial development, whereas Mrs Smith’s view was somewhat broader in that she considered the highest and best use, from a value point of view at least, was simply to hold the land for future development. ...

Argument The fundamental points brought out by counsel for the appellant were that although there was no written partnership agreement in the years 1965 to 1969, this should be no bar to the arrangement being considered a partnership; that architects and other professionals can accumulate and sell goodwill; that the basis for the calculation of the amount of goodwill in this case had been adequately supported; and although the business was small, it should nevertheless be accorded the same opportunity to benefit from the sale of such goodwill as should be available to any larger operation. ...

From the limited information available to the Board, it must also be concluded that it was considered important by Star for that company's purposes that he (and his wife) be on the trips. ...