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Given her difficult situation and for the sake of her future financial security, her parents gave the appellant money on trips that she made to Germany, and also sent her money by mail; she did not deposit those funds at the bank, fearing that her husband might find out about her financial resources from letters sent by that institution. 3.06 Aware of the difficult economic circumstances in which Mr. ... Hereinafter called "THE TRANSFEREE" WHICH PARTIES have agreed as follows: — The transferor does hereby transfer and cede all of his rights, titles and interest in the immoveable property hereinafter described, unto the transferee herein, hereto present and accepting, namely: DESCRIPTION — An immoveable property situated on Hortie Street in the City of Pierrefonds, known and described as lot number TWENTY-EIGHT of the official subdivision of the original lot number TWENTY-ONE (21-28) according to the official plan and book of reference of Ste-Geneviève Parish. ...

At the Closing, the Issuer will execute and deliver to the Purchaser the Debenture, and the Purchaser will pay the purchase price to the Issuer as follows: (a) as to $24,000, by delivery of a cheque for $24,000 drawn on the trust account of Anderson, Baillie & Company, and (b) as to the balance, by delivery of a promissory note in the amount of $176,000 and substantially in the form attached hereto as Schedule B. 4. ... Finsbury Securities Ltd., [1966] 3 All E.R. 105; FA & AB Ltd v. Lupton, [1971] 3 All E.R. 948. ... The company used their organisation and their resources so that shareholders in Warshaw and in other companies involved should not wholly be deprived of money that had to be paid in tax. ...

Kotick wrote a letter to Revenue Canada — (Tab 4 of Exhibit A-1) outlining the fact that since May of 1991 the Appellant had nothing to do with the Corporations and could not get information from Pollack. ... Submissions of the Appellant The Appellant’s Memorandum of Law and Argument states as follows: Appellant’s Memorandum of Law & Argument The issue in these matters is whether the Appellant, as a director of Country Pride Discount Stores Incorporated and Country Pride Leasing Incorporated (the “Corporations”), should be liable for the unremitted employee source deductions of the Corporations, or whether the Appellant is entitled to rely upon the due diligence defence in subsection 227.1(3) of the Income Tax Act, R.S.C. 1985, c. ... Rather than treating directors as a homogenous group of professionals whose conduct is governed by a single, unchanging standard, that provision embraces a subjective element which takes into account the personal knowledge and background of the director, as well as his or her corporate circumstances in the form of, inter alia, the company’s organization, resources, customs and conduct. ...

For example, Article 25.00 — Fringe Benefits makes reference to a number of matters including the provision of “research monies” and funding for “professional development” and allocates the sum of $60,000 for the support of research in each academic year to be distributed amongst the various faculties. ... In order to do so, aside from certain funds received from the University, [9] he was required to pay the travel expenses so incurred out of his own resources. ... T.D.). 12 /?. v. Patterson, supra; Betz v. Minister of National Revenue (1987), 87 D.T.C. 5223 (Fed. ...

.: — This is an appeal from an assessment dated December 22, 1995 issued by the Minister of National Revenue pursuant to section 160 of the Income Tax Act. ... Medland purchased a residence at 14582 — 18th Avenue, Surrey, British Columbia (the “Property”) for a purchase price of $115,000.00. ... First, the term property is given a wide import by section 248 of the Act; it is defined as follows: “property” means property of any kind whatever whether real or personal or corporeal or incorporeal and, without restricting the generality of the foregoing, includes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, (c) a timber resource property, and (d) the work in progress of a business that is a profession. ...

Quebec was certain prior to entering the transaction that it would make a gain of $ 14,000. ... Finsbury Securities, Ltd., [1966] 3 All E.R. 105 and FA & AB Ltd. v. ... The company used their organisation and their resources so that shareholders in Warshaw and in other companies involved should not wholly be deprived of money that had to he paid in tax. ...

The amounts claimed were: 1982 25% = $1,712,500.00; 1983 50% = $3,425,000.00; 1984 25% = $1,712,500.00. ... Oppal 1983 5 $31,793 $2,470 $29,323 3 On February 22, 1979 International Resource Recovery Inc. ... In the course of his opening statement counsel for the appellants said: The machine that is central to this controversy was created — and I expect the evidence will demonstrate — was created between 1979 and 1981 or '82. ...

(the "payer") was not insurable within the meaning of the Unemployment Insurance Act (now the Employment Insurance Act) (the " Act ") since there existed between the appellants and the payer no contract of service within the meaning of paragraph 3(1)(a) of the former Act and paragraph 5(1)(a) of the new Act during those periods. ... (A-1470-92), the Federal Court of Appeal describes the function of a Tax Court of Canada judge, and I quote: "... ... Finally, she stated that she had been mistaken and that she had worked for the payer in 1993. [15] She worked at 1480 and 1490 Painter Circle in Ville St-Laurent. [16] She worked from 2:00 p.m. or 3:00 p.m. until midnight. [17] She washed the stairs, cut the lawn, cleaned the mirrors and the garage, removed the snow outside, watered the plants and gathered up the leaves. [18] She was laid off by Mike Tsakalis on December 31, 1993 because there was a shortage of work. [19] She was paid once a month, by cheque, and received $400 a week. [20] In cross-examination, she stated that she had done no plumbing or electrical work. [21] She did not go to pick up the rent from the tenants. [22] She did not do painting work. [23] She never saw Jimmy Tsakalis, yet he went by to check on things. [24] She remembers meeting an investigator from Human Resources Development Canada (HRDC) but could not give the date. [25] She remembered that the investigator showed her a photograph of a person she identified by the name of Tasso. [26] She said there were many people in the building. [27] She said that another person worked for a brief period of time, but could not provide further explanation. [28] She did not know whether the payer deducted taxes in calculating the amount of her pay cheques. [29] She received her record of employment from Mike Tsakalis. [30] She acknowledged her signature on the statutory declaration (Exhibit I-1) dated February 13, 1996. [31] She said that there were four apartments per floor at the places where she had worked. ...

.: — The appellant appeals from assessments of income tax for the 1991, 1992 and 1993 taxation years. ... He held the view that a business plan was a document usually required to induce a financial institution into loaning start-up money and, since he was going to rely entirely on his own resources, he did not feel a written plan was necessary. ... It was a 2- axis machine in which he used a software program — basically a motion control card- that he had purchased and then programmed code to meet his specific needs. ...

I cannot, therefore, find — nor would I find on the evidence before me — that Mr. ... The provision embraces a subjective element which takes into account the personal knowledge and background of the directors, as well as his or her corporate circumstances in the form of, among other things, the company’s organization, resources, customs and conduct. ... Giglio owned 50 per cent of the shares of Patersil. 2 /?. v. Giglio, [1997] 2 C.T.C. 2608 (T.C.C.); order issued February 21, 1997. 3 (1988), 88 D.T.C. 1531 (T.C.C.) 4 Subsection 121(2) states that “a resignation of a director becomes effective at the time a written resignation is received by the corporation...” 5 Appellant’s counsel, Mr. ...