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., for the Federal Court of Appeal, stated at page 6264: [...] the general principle defining an “allowance” for purposes of paragraph 6(1)(b) is composed of three elements. ... C.A.) at 6176: [...] Even when these amounts are not used for any improper purpose, and even when they are reasonable estimations of the costs, our law treats them as additional remuneration, not as reimbursement of expenses, which require detailed receipts being submitted for reimbursement. ...

In so reassessing the Appellant, the Minister made the following assumptions of fact: a) The facts admitted above; b) The Appellant is a corporation incorporated pursuant to the laws of the Province of Saskatchewan and is engaged in a farming operation near Melfort, Saskatchewan; c) The Appellant’s taxation year ends on December 31; d) Lloyd James Taylor and Mary Jean Taylor are the sole directors and shareholders of the Appellant; e) On November 4, 1993, Lloyd Taylor entered into a “Contract for the Sale of a New Farm Implement — Form A” (the “Contract”) with Farm World for the purchase of the Farm Machinery; f) The Farm Machinery was to be delivered, according to the Contract, by December 31, 1993; g) Farm World is a dealership handling new and used farm equipment in the Province of Saskatchewan: h) Farm World ordered the Farm Machinery on November 4, 1993 from the manufacturer, Ford New Holland Canada Ltd.: 1) The manufacture of the Farm Machinery was completed on February 7, 1994: j) The Farm Machinery was shipped from the manufacturer to Farm World on February 14, 1994; k) The Farm Machinery was delivered to the Appellant on April 15, 1994; l) The retail date for warranty purposes was recorded by the manufacturer as March 18, 1994; m) As part of the consideration for the sale, the Appellant traded in a John Deere 8960 tractor (the “Trade-in”); n) The Trade-in was received by Farm World on November 30, 1993; o) The balance owing under the Contract was $18,000.00 which was paid by the Appellant by a cheque dated December 31, 1993; p) In the 1993 taxation year, the Appellant did not acquire, obtain title to nor have all of the incidents of ownership such as possession, use and risk of the Farm Machinery; q) The Farm Machinery was not in existence, produced, nor in a deliverable state as at December 31, 1993; and r) In reporting income for its 1993 taxation year the Appellant: 1) claimed Investment Tax Credits in the amount of $17,570.00 to which it was not entitled; and ii) under-reported the amount of recapture of depreciation by $175,454.00. ... On November 4, 1993, Lloyd Taylor, on behalf of the Appellant, entered into a “Contract for the Sale of a New Farm Implement — Form A” (the “Contract”), which is Document #3 in this Request to Admit, with Farm World Equipment Ltd. ...

Furthermore, the law firm, the partnership, Waterbury, Newton & Johnson, is not now and never has been a shareholder of Webster Field Holdings Limited, that they're separate and distinct. ... To the foregoing he added: The law firm Waterbury, Newton & Johnson, I became a partner in the year 1969. ...

Those vicissitudes include the reality of cash flow shortage. 18 However, it should be noted that this passage is immediately followed by this analysis of the facts:...The directors were aware of the GST quarterly payment obligation, they made what seem to me to be, in their circumstances, reasonable arrangements for the payment of same and certainly did their best to ensure that the continuing failure to pay would be dealt with. 19 To highlight the duty of the director to the corporation, counsel for the appellant cited an article by attorneys Jean-Pierre Roy and Jean-François Gaudreault-Desbiens, entitled “ L'appréciation de la responsabilité des administrateurs et l'utilisation du critère subjectif dans la Loi sur le ministère du Revenu ”, published in Revue de planification fiscale et successorale, Vol. 13, Nº 3, at page 325. ...

The year under appeal is 1993. 2 In computing her tax payable for 1993 the appellant deducted an amount determined under subsection 118.3(1) of the Income Tax Act (“the Act ”). It provides: Where (a) an individual has a severe and prolonged mental or physical impairment, (a.1) the effects of the impairment are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (a.2) a medical doctor, or where the impairment is an impairment of sight, a medical doctor or an optometrist, has certified in prescribed form that the individual has a severe and prolonged mental or physical impairment the effects of which are such that the individual's ability to perform a basic activity of daily living is markedly restricted, (b) the individual has filed for a taxation year with the Minister the certificate described in paragraph (a.2), and (c) no amount in respect of remuneration for an attendant or care in a nursing home, in respect of the individual, is included in calculating a deduction under section 118.2 (otherwise than because of paragraph 118.2(2)(b.1)) for the year by the individual or by any other person, for the purposes of computing the tax payable under this Part by the individual for the year, there may be deducted an amount determined by the formula A × $4,118 where A is the appropriate percentage for the year. ...

.: — The appeals of Rajesh Monga were heard in Toronto under the Informal Procedures of this Court on common evidence with the appeals of Neera Monga and Edmundo Sanchez. ... (v) 2205-24 Wellesley Street Claimed, 1991 Claimed, 1992 interest $8,156.00 NIL (plus) other expenses $20,021.87 $31,400.45 total expenses $28,177.87 $31,400.45 gross rental income $10,350.00 $12,000.00 (minus) net loss $17,827.87 $19,400.45 muttiplied by) % ownership 100% 100% pro-rated net loss $17,827.87 $19,400.45 The Sheppard Property would generate rental income of $1,200 per month. ...

She of course will give you one-halt of her Canada Pension (as adjusted — if she has one). 7. ... Nelson — albeit expressed in gentler language such as,"she desires" or "she wishes" — but requesting that he agree to those terms in a separation agreement. ...

In 1978, the company was newly incorporated and its only business was the operation of the Red Barn on the SW‘/4 of section 29 — the only quarter section described in the lease. ... For its fiscal periods ending the 30th day of June, the company paid to Cochrane and Jerram rents which were allocated between the Red Barn and the Wildlife Park as follows: Red Barn Wildlife Park Total Total 1978 $10,000 $ 0 $10,000 1979 $15,600 0 $15,600 1980 $14,000 $ 5,680 $19,680 1981 0 $25,000 $25,000 1982 0 $25,000 $25,000 1983 0 $25,200 $25,200 1984 0 $25,400 $25,400 1985 0 $21,500 $21,500 1986 $16,700 0 $16,700 For each of the years 1981 to 1985, the operating loss at the Wildlife Park exceeded the profit at the Red Barn by an amount which, on average, was approximately $240,000. ... The company paid and deducted the municipal taxes on the SW / of section 29. ...

M.N.R., [1964] C.T.C. 175, 64 D.T.C. 5103; O & M Investments Ltd. v. ... & M. Marcus Investments Inc. ("Marcus"). Slavens Real Estate is described in the agreement as "agent". ... Larry of Robins, Appleby, Kotler, Banks & Taub wrote Tridel Corporation. ...

Then, at the bottom of page 6, Vanden Berg- according to the minutes- stated: "... contractors are only paid for work. ... Vanden Berg operates through a corporation, Vanden Berg & Associates Inc. ... In the within appeal, Ardyth Cooper's attitude was borne out by the comment that " if it ain't broke don't fix it". ...