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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. ...

Lord Denning in Hosegood v Hosegood (1950), 66 TLR 735 at 738, in a civil case, put it this way: When people say that a man must be taken to intend the natural consequences of his acts, they fall Into error: there is no “must” about #; it is only "may”. ...

Thereafter interest would be an even $5,000 per annum at 10% [1] *. The amount of $7,207.98 written off in 1968 had been set up as an asset and income tax paid on same in 1967 as it was not until 1968 that it was considered to be a bad debt. ...

In cross-examination, he said that to him this site represented “... a possible opportunity for a modest-sized site”. ...

On April 5, 1960 these two men entered into what is commonly known in the legal profession as “a buy-sell agreement”, whereby the survivor had the right but not the obligation to purchase the shares of the deceased. (! ...

In Sutton Lumber & Trading Co, Ltd v MNR, [1953] 2 S.C.R. 77; [1953] CTC 237; 53 DTC 1158 Locke, J said at page 83 [244, 1161]: The question to be decided is not as to what business or trade the company might have carried on under its memorandum, but rather what was in truth the business it did engage in.... ...

The only case which I have been able to find in which this section was discussed at all was in the Tax Appeal Board judgment in the case of Renown Steel & Services Limited v MNR, [1969] Tax ABC 678, which held that since subsection 39(6) is an exempting provision it must be strictly construed and as on the facts of the case the controller held the shares as a guarantor and not as a maker of a loan, he did not come within the provisions of subparagraph 39(6)(b)(i) so that the companies were held to be associated. ...

N 0 witnesses were called by either party and no explanation was given as to the discrepancy of $13,350 between the amount of the accounts ■ collected by Mrs. ...

Again, in concluding, he stated at page 212: On the whole I am of the opinion that. when, as a result of an appeal, the judicial authority set up has an assessment referred to it, the ministerial authority no longer has jurisdiction in the * matter and can no longer act until the court has passed judgment between the parties concerned. ...

& Cr. 359, Lord Chancellor Cottenham adopts the definition of Lord Eldon in Ex parte Pye (supra) and says, p. 367: “Lord Eldon says, it is a person ‘meaning to put himself in loco parentis; in the situation of a person described as the lawful father of the child’; but this definition must, I conceive, be considered as applicable to those parental offices and duties to which the subject in question has reference, namely, to the office and duty of the parent to make provision for the child. ...