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At all material times, the appellant's five directors were those mentioned below and opposite each name is shown the percentage in the appellant's shareholdings held directly or indirectly by each director from the time of incorporation to October 29, 1986: Laurent Lebel 20 % Connie Laidlaw 20% Frank Mueller 16.7% George Mueller 10% Gerald Metheral 33.3% George Mueller and Gerald Metheral were respectively appointed president and secretary of the appellant, as appears from a resolution dated November 20, 1978. ... In this connection, the financial statements of the appellant also show that the following management fee expenses were paid by the appellant to Delco in respect of the appellant's taxation years mentioned below: 1981 $ 97,735.44 1982 $115,021.23 1983 $107,437 1984 $ 29,400 1985 $ 23,705 With respect to management fees, the financial statements for the year ended October 30, 1984 reflect a change in accounting practice. ... As far as the contributed share capital in the appellant's shareholdings made by each shareholder, it was nominal and no inference could, of course, be made that it related to the financial resources or investment wishes of each shareholder. ...

Act- Case Law — Analysis 4.01 Act The principal provisions of the Income Tax Act applicable in the instant appeal are paragraphs 160(1)(a) and (e) and subsections (2) and 248(1) (definition of the word "property"). ... "There is none — moreover, this is why you have an assessment issued with a number, there is no taxation year in question for the recipient" (trans, pp. 90-91). 4.04.3(2) As to the fact that the notice of notification mentions the taxation year 1985 (para. 3.02.6), counsel added: Further, the notice of notification cannot be used to argue that the Minister chose a year, because this is simply a matter of procedure, and if there are clerical errors in the notice this does not fundamentally vitiate the assessment. ... Only subparagraph 160(1)(3)(ii) refers to this, but to specify the amount of tax owed by the transferor of property ”... in respect of the taxation year in which the property was transferred or of any preceding taxation year". ...

Rather than treating directors as a homogeneous 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. ... Rather, the Act contains both objective elements — embodied in the reasonable person language — and subjective elements — inherent in individual considerations like “skill” and the idea of “comparable circumstances”. ... He says that Cooper & Lybrand (“C&L”), the accountants, gave him documents to sign and relying on their professional expertise, he signed those documents for filing with Revenue Canada. ...

I was there as an external resource. I was there to bring in new business and new profits. ... We were in the — basically in the ladies' pants business, you know. ... We find that on November 14, 1986 Tedco apparently transferred the following Tangerine shares to Algo: — 3,000 class A common shares; — 1,100 class A preferred shares; — and 98,094 class B preferred shares (3.36(b)). ...

(“McLeod”), a wholly owned subsidiary of McLeod, Young, Weir & Company Ltd., Stockbrokers. ... By cable of November 9, 1978, Penturn advised Samuel Mortgagu & Co. ... You, personally, or John Penturn & Son? A. John Penturn & Son. ...

"), the following amounts: 1981 $123,936 1982 $ 89,698 1983 $ 75,282 1984 $ 71,360 1985 $ 62,592 [admitted (paragraph 1 R.A.N.A.)] 2. ... The dividends which the appellants and 2154 received totalled as follows: LUDCO Augustus Justinian TOTAL 1978 — — 1979 $ 11,734 — $ 11,734 1980 23,338 $ 28,589 51,927 1981 24,038 29,446 53,484 1982 23,728 29,216 52,944 1983 24,818 30,341 55,159 $107,656 $117,592 $225,248 2154 1984 $24,884 $30,549 $ 55,433 1985 26,334 32,308 58,642 $51,218 $62,857 $114,075 BRIAN 1979 — $ 8,591 — 1980 — 7,793 — 1981 — 7,950 — 1982 — 8,256 — 1983 — 8,313 — 1984 — 8,313 — 1985 — 9,233 — $58,449 $58,449 CINDY 1979 $ 8,591 — 1980 — 7,793 — 1981 — 7,950 — 1982 — 8,256 — 1983 — 8,313 — 1984 — 8,313 — 1985 — 9,233 — — $58,499 [sic] $58,449 DAVID 1979 — $ 8,591 — 1980 — 7,793 — 1981 — 7,950 — 1982 — 8,256 — 1983 — 8,313 — 1984 — 8,313 — 1985 — 9,233 — $58,449 $ 58,449 $175,347 GRAND $514,670 TOTAL: Exhibit A-60, volume VII, page 1306. ... The ineligible uses include: — exempt income; — life insurance policies; — personal consumption; and — making of capital gains. ...

Further, during this period of time his financial resources were limited and he could only afford lower quality properties. ... Further he says that even though some of them were foreseeable his limited financial resources and the limited time available for farming prevented him from taking "proactive steps to avoid them". ... Unless the amount reasonably expected to be earned from farming is substantial in relation to other sources of income then farming will at best be regarded as a “ sideline business” to which the restriction on losses will apply in accordance with subsection 31(1). ...

The following excerpts from the judgment of Hugessen, J. in Smith, Kline & French Laboratories Ltd. v. ... Assuming there is room under s. 15 for judicial intervention beyond the traditionally established and analogous policies against discrimination discussed by my col- league, it bears repeating that considerations of institutional functions and resources should make courts extremely wary about questioning legislative and governmental choices in such areas. ... If paragraph 122.2(2)(a) is invalid it falls, and in the absence of legislative action to fill the void it cannot be said that the appellant is, within the meaning of subsection 122.2(1), ”... an individual who has an eligible child... ...

Fontaine stated no such cheque- in the sum of $4,000 or $4,040- was ever located when searching through SRC records, including statements on the TD account which was the only one used by that company. [148] Fontaine stated he calculated the amount of work needed to qualify for UI benefits for various appellants in the within appeals together with the amount of overpayment- according to HRDC- and the amount of the penalties imposed administratively by the relevant Insurance Officer in accordance with the provisions of the Act, as follows: Name of appellant                     Weeks to qualify           Overpayment     Penalty              Total Sharinder Singh Bagri                            17                     $2,582              $1,601              $4,183 Ajmer Kaur Gill                                     26                     $4,784              $1,664              $6,448 Bhagwant Kaur Grewal                         17                     $2,752              $1,576              $4,328 Varinder Kaur Jassal                             26                     $4,862              $1,497              $6,359 Prabhjot Kaur Minhas                           20                     $5,934              $1,935              $7,869 Bakhshish Kaur Thandi              17                     $4,320              $1,404              $5,724 Gian Singh Thandi                                  17                        $980                 $544              $1,524 [149] Fontaine pointed out that in the case of Prabhjot Kaur Minhas, she needed 20 weeks employment if her claim for UI benefits was based on maternity leave. ... Blakely stated his supervisor asked him to contact Michel Fontaine who had requested that a resource person from the rulings office be available to assist HRDC in respect of a large-scale investigation. ... Blakely stated he regarded his role as that of a resource person but did not attend any interview with any ICO other than Fontaine. ...

Related to the demonstration of progress for the first year, a research program of this scope would involve as much as two to five years of startup time, particularly with the small size of personnel resources. ... This surely would include repeatable experiments in which the steps, the various changes made and the results are carefully noted. 1 lt reads: 194. (2) In this Act, the “Part VIII refund" of a corporation for a taxation year means an amount equal to the lesser of (a) the aggregate of (i) the amount, if any, by which the scientific research and experimental development tax credit of the corporation for the year exceeds the amount, if any, deducted by it under subsection 127.3(1) from its tax otherwise payable under Part I for the year, and (ii) such amount as the corporation may claim, not exceeding 50% of the amount, if any, by which (A) the aggregate of all expenditures made by it after April 19, 1983 and in the year or the immediately preceding taxation year each of which is an expenditure (other than an expenditure prescribed for the purposes of the definition “ qualified expenditure" in subsection 127(9) claimed under paragraph 37(1)(a) or (b) to the extent that such expenditure is specified by the corporation in its return of income under Part I for the year exceeds the aggregate of (B) the aggregate of all expenditures each of which is an expenditure made by it in the immediately preceding taxation year, to the extent that such expenditure was included in determining the aggregate under clause (A) and resulted in (I) a refund to it under this Part for the immediately precedingtaxa- tion year, (II) a deduction by it under subsection 37(1) for the immediately preceding taxation year, or (III) a deduction by it under subsection 127(5) for any taxation year, and (C) twice the portion of the aggregate of amounts each of which is an amount deducted by it in computing its income for the year or the immediately preceding taxation year under section 37.1 that can reason ably be considered to relate to expenditures that were included in determining the aggregate under clause (A); and (b) the refundable Part VIII tax on hand of the corporation at the end of the year. 2 information Circular 86-4R was issued on September 25, 1987. 3 As will be seen from what has already been said in relation to Professor Snelgrove's evidence, the three criteria referred to in paragraph 2.10 of 1C86-4R2 are the criterion of scientific or technological advancement, the criterion of technologi cal uncertainty and the criterion of scientific and technical content. ...