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Nor can such requirement be considered as implicit in the contracts, and the Board has no alternative but to apply strictly the wording of paragraphs 11(10)(b) and (c) and to conclude that the rental expenses and the cost of supplies are not deductible. ...

Counsel also referred to the notification by the Minister (Form T2008A) addressed to the appellant and which reads in part: The Honourable the Minister of National Revenue having reconsidered the assessments and having considered the facts and reasons set forth in the Notices of Objection hereby confirms the said assessments as having been made in accordance with the provisions of the Act and in particular on the ground that the Minister has determined that in the taxation years 1968 and 1969 the taxpayer's chief source of income was neither farming nor a combination of farming and some other source of income and therefore his farming losses have been allowed to the extent of $5,000.00 in each of these years in accordance with the provisions of section 13 of the Act. ...

He said that he considered there were sufficient cherry trees in the orchard to more than cover the costs of operation, cherries being a high-income-producing type of fruit. ...

On that valuation, the appellant indicated that he considered his 40% interest to be worth $40,000, and this was the formula that had been used in arriving at $37,500 as the amount of the settlement. ...

The nature of its activities is such that the company cannot be considered to exist as an active commercial business but merely as one holding investments. ...

Being so, subsection 16(1) of the Act should be considered. Said section reads as follows: 16. (1) A payment or transfer of property made pursuant to the direction of, or with the concurrence of, a taxpayer to some other person for the benefit of the taxpayer,... shall be included in computing the taxpayer’s income to the extent that it would be if the payment or transfer had been made to him.” ...

Counsel on behalf of the Minister alleges that by no stretch of the imagination can a purchase for $1,500 of the shares of this company along with a “worthless” note for $80,000 odd be considered an investment. ...

Brown describes Hambeldon Estates Ltd. as a personal corporation and it was apparently considered such by at least one of its financial advisers; see exhibit 15 to that affidavit. ...

Ross also said he considered that Clearmonte Holdings Ltd. paid the appellant $20,000 for his interest in the so-called Winterburn farm. ...

She did not get any salary from her own company for the said years but received $5,600 from it as salary in 1973 and $12,000 in 1974. 5 She also owns a duplex that she acquired in 1959, but the said asset was not transferred to the company because she considered that this property was producing rental, and not business, income and therefore was a well-secured personal investment. 6 She explained that the company's business was the lending of money at high interest rates and for short periods of time. ...