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The section which must be considered to decide whether or not the appellant has been correctly assessed is subsection 15(2) of the Income Tax Act. ... As to the date of the mortgage, counsel submitted that a verbal agreement to give the mortgage was sufficient to be a mortgage and therefore the agreement, which was reflected in the accountant’s note and journal entries and corroborated by the appellant, was sufficient to consider the mortgage to be given and to be considered before the end of 1975 as repayment of the loan. ...

Counsel for the respondent submitted that, since the trustee is the one who could vote at a shareholders’ meeting, it is he who is considered when one comes to consider control, not the beneficiary. ... Another case which should be considered because of the death of Monrad Wigen is the Federal Court judgment in H A Fawcett & Son, Limited v Her Majesty the Queen, [1979] CTC 303; 79 DTC 5224, (now under appeal to the Federal Court of Appeal). ... Following the death of Monrad Wigen, the control of his shares in Logging shall be considered to be with Rose K Wigen. ...

Since the St Felicien plant did not materialize and did not at any time operate, can the expenses already incurred by the appellant as laid down costs of the legal acquisition of timber rights which were never used, be considered as a true capital expenditure? ... I do not indeed feel that merely because the expenditure was made for the purpose of determining whether to bring into existence a capital asset, it should always be considered as a capital expenditure and, therefore, not deductible. ... Why was it not considered necessary to transfer these assets back to the appellant? ...

Some of them would last a year or two and in that time, if all repairs were considered to have been done, they may have been replaced one and one-half times. ... He continued that it was not within the scope of paragraph 18(1)(b), but rather, that expenditure should be approached and considered in the same fashion as the Exchequer or Federal Court approached similar expenses in several cases. ... He did not suggest that those cases were the same as or similar to this appeal, but rather submitted that when the issue in this appeal was being considered, the same consideration should exist as those cases set forth. ...

The appellant in his argument said that many Western farmers considered such advances under the said Act as interest-free loans and that “Good Farming”, a farming magazine had used this terminology in a number of its articles which had indicated to him and probably to many others that advance payments could properly be held in suspense until the year of actual delivery of grain. ...

The farming Operation was considered to be so extensive, that in 1974 a tax department auditor advised the Appellant to claim full losses for the farm. 10. ...

I might also refer to the Reasons of Mr Justice Rand where he said at 713: It is, I think, misleading to convert a transaction of this sort into what is considered to be its equivalent and then to attribute to it special incidents that belong to the latter. ...

Indeed, if the teacher exchange program, under which the appellant went to Australia, could be considered as a “prescribed international development assistance program of the Government of Canada”, as stipulated in paragraph 250(1)(d), the appeal would be allowed. ...

The information he received was that the deposit of $5,000 could be considered as a bona fide purchase. ...

As explained by the appellant’s accountant, in preparing its statement of profit and loss for the year, only cash receipts and cash disbursements were considered. ...