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.: — The appellant elected to have his appeals, from the assessments of the Minister of National Revenue (the “Minister”) for his 1987 and 1989 taxation years, heard under the Informal Procedure. ... Outside of his viva voce evidence to that effect, the only other evidence in support of this position is the T5013 Supplementary Statement of Partnership Income slip, in the name of “687420 Ontario Limited & T.E. ...

. … 4. Prior to February 9, 1988, Mrs. Avery contacted her accounting and legal advisors in order to determine how to structure the transaction whereby she would relinquish her interest in Westminster to her brother. ... Notwithstanding paragraph 13(b), if the appellant’s tax return had been filed properly according to the instructions in the planning memorandum, a designation would have been made under paragraph 55(5)(f) which would have resulted in the realization of a capital gain of $389,553 (($700,000 (proceeds)-$270,978 (deemed dividend- safe income))- $39,469 (acb) = $389,553). ...

Obviously, the time of failure must be the time when a person failed to file a return — namely April 30 in the year following the taxation year in question. ...

Davis pointed out that the 1988 statements included, under current assets, a note receivable — Malcan Packaging for $97,750 and under current liabilities the sum of $116,571.32 as advances from a director. ... Both of these returns reported nil income, that its major business activity was inactive — no assets and that Mr. ...

Campbell & Co. Inc. in connection with a company known in the pleadings as "Coral"; 3. the background, composition, function, activities, organization and income of ARMC and ARMC No. 2; 4. the prosecutions brought by the U.S. government against Allen F. ... Campbell & Co. Inc. and the knowledge that certain persons may have concerning the bringing of those prosecutions; 5. the function and activities of Coral, particularly in Brazil, the nature and location of its operations and where its premises are located; 6. the transactions and arrangements entered into or concluded between ARMC and ARMC No. 2 and Coral regarding, in particular, research work and the function of the promoters of ARMC and ARMC No. 2; 7. the use of Brazilian currency by Coral and by the promoters and members of ARMC and ARMC No. 2, the characteristics of that currency, the anticipated depreciation of the currency, the measures taken by the Brazilian government regarding it and the business practices followed in the transactions conducted in the currency; 8. the "hedge agreement" between Coral, ARMC and ARMC No. 2 and the protection provided to ARMC and ARMC No. 2; 9. the nature and value of the notes signed by ARMC and ARMC No. 2 in favour of Coral and the assignment of those notes to a trustee, M.R.T. ...

EQUALIZING PAYMENT — NET FAMILY PROPERTY The husband and the wife agree that during their marriage certain items of property were acquired by both of them and that those items of property were used by the family without regard to the identity of the person acquiring the property. ... Notwithstanding section 1, I cannot ignore the fact that section 14 is preceded by the heading "Equalizing Payment — Net Family Property"; and the phrase "net family property" is defined in section 4 of the F.L.A. ...

The returns were prepared by a firm of chartered accountants, Tierney & White, who had prepared unaudited financial statements for 1987. ... All the financial statements and tax returns were prepared by Tierney & White. ...

It doesn't seem to — it’s not a drug that makes a dramatic change. ... If I’m out and I have to do a great deal of walking, I — at the Stampede and Expo I I visited, I used a wheelchair when I was there. ...

A copy of the invoice from the law firm of Berger & Winston dated July 15, 1987 is enclosed as (Exhibit B). ... Following various exchanges of letters between the appellant’s agents and those of the respondent, a letter was sent by the agents of the respondent to the appellant’s accountant informing him that the deduction of the legal fees incurred by the appellant would not be allowed for the 1987 and 1988 taxation years because insufficient information had been provided (Exhibit A-8 — Letter dated August 17, 1989, from the audit division to the Estate of Kelly Waxman, c/o Richard Venor). ...

Subsection 34(6) reads as follows: (6) Section 56 of the said Act is further amended by adding thereto, immediately after subsection (11) thereof, the following subsection: (12) Subject to subsections 56.1(2) and 60.1(2), for the purposes of paragraphs (1)(b), (c) and (c.1) (hereinafter in this subsection referred to as the "former paragraphs”) and 60(b), (c) and (c.1) (hereinafter in this subsection referred to as the “latter paragraphs"), “ allowance” does not include any amount that is received by a person, referred to in the former paragraphs as "the taxpayer" and in the latter paragraphs as "the recipient", unless that person has discretion as to the use of the amount. ... In Gagnon, supra, the Supreme Court of Canada thus held that the monthly payments in question made by the taxpayer were “ allowances” within the meaning of paragraph 60(b) of the Income Tax Act. ...