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Between the years 1974 and 1977 the appellant reported the following income and expenses with respect to the raising of race horses on this property; Year Income Expenses 1974 $ 55 $ 3,097.00 1975 nil 11,268.19 1976 1,200 13,273.00 1977 2,000 16,587.00 The relevant section to be considered is section 31 of the Act which reads as follows: 31.(1) Where a taxpayer’s chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deductions in respect of expenditures described in section 37, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) /2 of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500, and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words “and before making any deductions in respect of expenditures described in section 37’’ were deleted, exceeds (ii) the amount determined under subparagraph (a)(i); and for the purposes of this Act the amount, if any by which the amount determined under subparagraph (a)(i) exceeds the amount determined under subparagraph (a)(ii) is the taxpayer’s “restricted farm loss’’ for the year. (2) For the purpose of this section, the Minister may determine that a taxpayer’s chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income. ...

See also John W Welton v MNR, [1978] CTC 3153; 78 DTC 1848, which is very similar in facts to the case before me, whereby the appellant considered not reporting gain as income because he was under the impression that the sale of a residence was not taxable. ...

On the balance of probabilities, this case must be considered on the facts and I have no hesitation whatsoever in concluding that any properties held in one of the single names of either Sam or Israel Feder were held in trust for the beneficial interest of their spouse and that all assets acquired and disposed of by them were disposed of as an equal and joint interest. ...

The Town was under some economic difficulties and there were no demands for additional lots — hence, no land divisions for which municipal services would have had to be provided were being considered by the municipal board. ...

In assessing the appellant, the Minister of National Revenue assumed that the investment income of $7,392.54 was paid or credited to the appellant’s account with the Canadian Bank of Commerce Trust Company (Caribbean) Limited (Caribbean Bank) and considered that the appellant could have dealt with his Caribbean income as he wished, with the exception of transferring it to Canada. ...

. — From the foregoing, it is considered that our corporation is engaged in an active business. ...

Minister of National Revenue, [1981] CTC 2665, 81 DTC 604 The Chairman:—The appeal of Kadon Development Corporation is from an assessment with respect to the 1977 taxation year by which the Minister considered as income the appellant’s active business profit in the amount of $33,878 realized from the sale of a property situated at 731-733 Lindsay Road, Richmond, British Columbia. ...

This fact does not of itself necessarily constitute an insurmountable obstacle to the application of section 167 of the Act, but it is certainly an important factor to be considered before the application can be allowed. ...

Article XXII provides that the accompanying Protocol is to be considered “an integral part of the Convention’’. ...

It was strongly argued by the primary debtor that it was only for the purpose of determining whether an action could be brought without demand that the rule was established that a demand note was due at all times after its delivery, as the institution of an action was considered equivalent to a formal demand; but such cases as Norton v Ellam, 2 M & W 461; Re Brown, [1893] 2 Ch 300, at 304; Edwards v Walters, [1896] 2 Ch 157, at 162, Boulton v Langmuir (1897), 24 AR (Ont) 618, at 622, show that a demand note matures for all purposes as soon as it is delivered: consequently, this demand note had matured and was due before action begun, and the original note could be sued on. ...