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. — If the return of a taxpayer's income for a taxation year has been made within 3 years from the end of the year, the Minister (a) may, on or after mailing the notice of assessment for the year, refund without application therefor, any overpayment for the year, and (b) shall, with all due dispatch, make such a refund after mailing the notice of assessment if application therefor has been made in writing by the taxpayer within (i) the 6 year period referred to in paragraph 152(4)(b), where that paragraph applies, and (ii) the 3 year period referred to in paragraph 152(4)(c), in any other case. ...

What was said by Dickson, C.J. in the extract cited above was that ‘’... the taxpayer must satisfy the Court that his or her bona fide purpose in using the funds was to earn income”. ...

The notice of assessment issue reads as follows: Revenue Canada Revenu Canada NOTICE OF ASSESSMENT Taxation Impôt AVIS DE COTISATION 10569 DATE OF MAILING — DISTRICT TAXATION OFFICE DATE DE MISE A LA POSTE BUREAU DE DISTRICT D'IMPÔT May 22, 1990 TORONTO See Reverse for Inquiry Details Your Remittance for the Total Amount Assessed Should be Forwarded with the Attached Milton Wallace Remittance Form (Part 2) 533 College Street Retain Top Portion (Part 1). ...

. $1.60 x 82,500 = $132,000) all pursuant to paragraph 7(1)(a) of the Act. ...

Appeal allowed. 1 (a) [TRANSLATION] ”... this compensatory allowance is not in any way a form of alimony”: La nouvelle legislation en matière familiale au Québec, Suzanne Pilon, Les Editions Yvon Blais, Inc., 1984, pp. 53 et seq.; (b) See also Jean Pineau and Danielle Burman, Effets du mariage et régimes matrimoniaux, Les Editions Thémis, 1984, pp. 89 et seq. ...

By September 30, 1980, the mortgages outstanding were: first mortgage — $8,803,863; second mortgage—$6,168,116; third mortgage—$662,154 for a total of $15,634,133. ...

(j) From 1980 to 1984, Les Sentiers Sauvages incurred the following losses: 1980 1981 1982 1983 1984 Advertising $ 501 158 67 Insurance 1,050 2,118 2,131 1,101 1,099 Interest 7,688 16,025 34,858 16,981 14,382 Taxes 274 825 879 1,332 994 Telephone, Light, Heat, Water 500 428 600 388 386 Truck 635 198 312 336 945 Office 96 126 Other Financial 23,125 C.C.A. 16,896 18,615 4,543 11,055 16,943 Loss $27,544 38,367 43,390 54,414 34,875 (k) At no time did the appellant formulate a business plan for Les Sentiers Sauvages, nor did he ever conduct any feasibility studies or market surveys. ...

In John's Canada Tax Words & Phrases, 1986 edition there is found at page U-5 "the first meaning assigned to the word use’ in Johnson's Dictionary is 'to employ to any purpose', it is therefore a word of wide signification.” ...

From the outset the appellant really dealt with Lot 77 for what it was — a legal entity. ...

London & West Riding Investments, Ltd., [1967] 1 All E.R. 518, at 528 as follows: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd. and the defendants were a "sham", it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ...