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., as he then was, stated at page 486 (C.T.C. 314, D.T.C. 5215-16): Whether a source of income is a taxpayer's “ chief source” of income is both a relative and objective test. ...

Appellant's counsel submitted ”... that should probably have been done by way of a salary from the company. ...

The word “ payable” is defined as"... that may, can or must be paid" (Webster's Ninth New Collegiate Dictionary, 1989, at page 864), and as: Capable of being paid; suitable to be paid; admitting or demanding payment; justly due; legally enforceable. ...

.:— On November 19, 1987, a notice of assessment was issued to the appellant in his capacity as a director of Lincoln Pub Ltd. (” Lincoln Pub”) with respect to unremitted source deductions owing when Lincoln Pub went out of business in September, 1986. ...

Certainly in order for estoppel to apply it would have to meet the three tests set out in Western Smallware & Stationery Co. ...

The respondent further argues if the Court holds that the $2,000,000 “ holding fee" is a "Canadian exploration expense” there was no liability in 1985 for such expense and the expense was not incurred by the limited partnership in respect of the drillship in the 1985 taxation year. ...

From this she concludes that from the beginning it was intended that all three lots be included in the " reserve". ...

Imaginamics, in tum, owned all of the issued and outstanding shares of the Bynamics Corporation (” Bynamics"). ...

He confirmed Exhibit A-25 which was a Summary of Farm & Employment Income between 1985 and 1989 but indicated there would be small differences in total. ...

Furthermore, the matter of the appellant's existing liability prior to the issue of the 1986 Order in respect of the maintenance payment that had fallen in arrears, was expressly dealt with in paragraph 3 of the 1986 Order which provides that, leaving out certain expletive words: ”... the arreas of maintenance as of May 31, 1986... are hereby fixed at $7,500.00.” ...