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As the parties were agreed, and respondent accepted the amount of $472.75 as an allowable deduction, the appeal is allowed in part only on that item, and in toto for the other question considered. ...

The Board dealt with the motion by ruling that the assumptions made by the Minister must be considered correct in so far as they are peculiarly within the knowledge of the taxpayer and that in order to decide whether the facts assumed are peculiarly within the knowledge of the taxpayer, it is necessary to hear him under oath. ...

With regard to the 1964 taxation year, I am prepared on the strength of the evidence adduced and not adequately refuted by the respondent, to accept in principle the appellant’s argument that Premura was his employer at that time and that the amounts transmitted to Premura by Transatlantic in that year were not to be considered as representing appellant’s personal income transferred to Premura at his direction. ...

Clearly respondent’s position under the Income Tax Act must be considered in the light of its proper application. ...

All things considered, I am unable to see any grounds upon which this appeal can succeed. ...

In this sale the appellant realized a profit of $107,056.64 which was considered as income from a venture in the nature of trade and reassessed as such by the Minister of National Revenue in the appellant’s pertinent taxation year. ...

The evidence further indicated that: the building was old and could not be considered a viable structure; the boiler and elevator were operating but in a shaky condition; a new roof was needed and the floors required extensive repairs; the property was in the area included in the Civic Centre Redevelopment Plan; the trend in that area was towards the construction of large office buildings; the old building had no place in the Civic Centre Plan; the price of land was moving up very quickly in the area; the appellant had a lease with North-West Tent & Awning Co Ltd which prevented demolition until December 31, 1967; the net return from the building amounted to about $8,000; the site is one of the choice locations in Edmonton; and, finally, the building was bought by a syndicate of lawyers at a time when there was a trend towards the construction of large buildings in Edmonton, requiring the assemblage of land to complete projects. ...

Similarly, I have no way of knowing whether a computer engineer or a technician with networking expertise could have employed standard networking procedures to connect the sensors to the Appellant’s customers’ networks. [24] Based on all of the foregoing, I find that Project 1 does not meet the first test. [25] I note that, as the Appellant never proceeded to the stage of attempting to develop algorithms, I have not considered whether that part of Project 1 would have met the first test. ...

From this it may be inferred that the Court in that case also considered that mining ended with extraction of the mineral from the ground. ...

Once again, let us bear in mind that the vendor alone is to be considered. ...