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Ouellette & Brett (supra). Later, he concluded as follows at page 2054 (D.T.C. 354): Accordingly, I find that the point at issue, as in In re Spiral et al. v. ...

The difference was explained in the following terms: [TRANSLATION] Q. [...] ...

., in conformity with Stubart, was careful to qualify the importance of a bona fide business purpose by stating that, although it "... is not determinative of the artificiality of the deduction”, it “is certainly relevant”. ...

. … The words “prevent” and “prévenir” mean the same: to stop an event from happening before it happens. ...

Robertson J.A. categorized the reported cases into two categories: those that deal with “inside directors” and those that deal with “outside directors” At page 263 (5416-17), he states: [...] it is difficult to deny that inside directors, meaning those involved in the day-to-day management of the company and who influence the conduct of its business affairs, will have the most difficulty in establishing the due diligence defence. ...

The appellant produced cases, uncontested by the respondent, which have held interest expense to be deductible where the interest expense exceeds the income from property (Alberta & Southern Gas Co. v. ...

("Allarco '); and (c) 840 owned all of the issued shares of 348841 Alberta Ltd. ...

These concerns arose from a series of events, including (a) his inability to cause the $20,000 cheque to be sent to Revenue Canada; (b) his failure to supply accurate statements showing the financial condition of the Corporation; (c) the fact that without Board authorization Jardine hired his wife as an employee of the Corporation; (d) his authorization to pay the sum of approximately $10,000 to Green, Haley & Pye for a restructuring report without receiving Board authorization; (e) his alleged verbal abuse of certain production employees of the Corporation; (f) his general habit of running the Corporation, making decisions and enforcing certain procedures without alerting the Board; and (g) his rosy projections of increased numbers of tourist buses and increased sales to customers, including a major customer, Jean Depot, which projections did not materialize. ...

Therefore, the maximum amount that could be assessed against the Appellant was $20,912 calculated as follows: Amount assessed under section 160 $52,662.30 Estimated value of the Appellant's shares according to evidence between $58,000 to $69,000 say    $63,500.00 One-half thereof to Mrs. ...

In 1994- according to Records of Employment – Exhibits R-4 and R-5- she worked 14 weeks for Doreen McMillan and 8 and 2/3 weeks for Almey. ...