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The issue was whether a sum of $48,207 can be considered a deductible capital loss in the 1974 taxation year. ...

As agent, Levitz probably had the authority to make the contract between General and Grouchy, and in effect General then had a bad debt, or certainly one which that company considered highly uncollectible. ...

I have carefully considered the evidence relating to a number of other areas in which the appellant claimed that the respondent erred. ...

Although the appellant kept records of his purchases and sales which were periodically compiled by his son and which the auditor considered, as well as those of Cecutti Bakery, the appellant’s accounting methods were quite rudimentary. ...

It is my considered opinion that the evidence, on account of its nature and, unfortunately, because of the way it was adduced, does not permit me to determine an amount that could be found to be fair and not arbitrary as being the aggregate taxable value of the property of the deceased. ...

To the extent that this motion is to be considered an appeal from the decision of the Minister which is hereby upheld, it is dismissed with costs. ...

The Plaintiff duly objected to the reassessment in respect of the 1971 taxation year, and on December 20, 1973 the Minister notified the Plaintiff that he had reconsidered his notification having considered the facts and reasons set forth in the Notice of Objection and confirmed that no tax was payable for the taxation year 1971. 7. ...

The Lees considered that this would be their family residence at some future date. ...

By all indications it was the governing factor in his considered decision to invest $2,000 of his own private and separate money early in November, rather than allow the prescribed administrative process of the Company to take its course and thereby ensure a direct transfer of the funds. ...

To establish the basis for my review of this matter, I would refer counsel to excerpts from the decision in Arthur E Kruger, Elmer D Bassani and Pantel Holdings Ltd v MNR, [1977] CTC 2311; 77 DTC 208, where I made the following observations at page 2321 [215]: In my opinion, to determine a question of the kind posed at this hearing, particularly dealing with the purchase and sale of land and considered against the background just described, requires the following: (a) an examination of the appellants’ personal and business circumstances at the time of acquisition, as such circumstances conflicted with, or complemented, the probable fulfilment of their stated intention- (b) a review of the efforts made and the progress demonstrated toward such stated intention as an objective; (c) a critical consideration of the reasons advanced for the eventual abandonment or the frustration of the stated intention. ...