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The taxpayer had been served three notices of reassessment in one year and the issue before the Tax Review Board was whether the reassessments were ” unfair and unreasonable” treatment by the Minister. ...

.: — This is an appeal from the decision of the Tax Court of Canada dated June 18, 1991, wherein it was held that subparagraph 40(2)(g)(ii) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

The documents consist of correspondence between counsel, correspondence from Coopers & Lybrand Limited and various accounting records and memoranda pertaining to the Thrush receivables. ...

Further, it was easier in the Sani Sport case to connect the loss of business opportunity with the property because, as Marceau, J.A. pointed out, this amount represented the “ particular economic value that the land had for the expropriated party". ...

. — Every person (other than a trustee in bankruptcy) who is an assignee, liquidator, receiver, receiver-manager, administrator, executor or any other like person (in this section referred to as the "responsible representative") administering, winding-up, controlling or otherwise dealing with a property, business or estate of another person, before distributing to one or more persons any property over which he has control in his capacity as the responsible representative, shall obtain a certificate from the Minister certifying that all amounts (a) for which any taxpayer is liable under this Act in respect of the taxation year in which the distribution is made, or any preceding taxation year, and (b) for the payment of which the responsible representative is or can reasonably be expected to become liable in his capacity as the responsible representative have been paid or that security for the payment thereof has been accepted by the Minister. (3) Personal liability—Where a responsible representative distributes to one or more persons property over which he has control in his capacity as the responsible representative without obtaining a certificate under subsection (2) in respect of the amounts referred to in that subsection, the responsible representative is personally liable for the payment of those amounts to the extent of the value of the property distributed and the Minister may assess the responsible representative therefor in the same manner and with the same effect as an assessment made under section 152. ...

The season within which it can operate is short — the beginning of July to the end of September. ...

The Court also referred to Denning, LJ, in Cardiff Rating Authority et al v Guest Keen Baldwins Iron & Steel Co, [1949] 1 All ER 27, who stated that one of the characteristics of a structure was that it was “intended to remain permanently on a permanent foundation”. ...

I understand that to be the frequently cited opinion of Lord Diplock in Snook v London & West Riding Investments, [1967] 1 All ER 518: I apprehend that, if [sham] has any meaning in law, it means acts done or documents executed by the parties to the “sham” which are intended by them to give to third parties or to the court the appearance of creating between the parties legal rights and obliations different from the actual legal rights and obligations (if any) which the parties intend to create. ...

The defendant, in 1975, paid the following: Mortgage $2,148.00 Taxes 655.99 Water & Sewer 151.50 Cablevision 59.40 $3,014.89 One-half of those amounts were paid for the benefit of the defendant’s former wife. ...

They are: …] find as a fact that the accused Bruce Relkie was the “directing mind” of the company respecting the filing of refund applications, in accordance with the identification theory of liability set out by the Supreme court of Canada in Canadian Dredge and Dock Company Ltd. v. ...