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In the second case, it was to please < tenant. When the buildings were constructed, they could have been retained because they were profitable and the appellant had the financial ability to continue to own them without too much effort. ...

In my view Voloudakis in the fullest sense of the word “ knowingly” failed to report amounts of taxable income. ...

I am of the opinion that even if counsel for the respondent had taken the approach suggested by counsel for the appellant there would have been practically no reduction in the time spent on the evidence — on this point, counsel for the appellant suggested a half-day. ...

These moneys have been set out in the reply “ Schedule A" and the appellant has accepted "Schedule A" [not reproduced] down to the point of “taxable income as reassessed". ...

It deducted the tax credit allowed by virtue of section 127.3 of the Act, that is to say, it calculated ”... tax payable by the corporation under Part I” for the 1984 taxation year as $5,704,134.87 being Part I tax after deducting a scientific research tax credit of $8,225,000 under section 127.3. ...

The word “ confer” means grant” or“ bestow”. In the respondent's reply to notice of appeal, in paragraphs 4(n) and (o) the following assumptions of fact are made: (n) at all material times, the appellant had appropriated the aforesaid $64,022.19 as funds or property of David Robinson Ltd; (o) a benefit or advantage has been conferred on the appellant by David Robinson Ltd. ...

The assumption “ if Part I were applicable” is difficult to apply because Part I applies on two different bases, depending on whether the taxpayer is a resident or nonresident. ...

In reply to the appellants notice of appeal, the respondent ceased to rely on subsection 14(1) of the Act, and stated the opinion that the project received by the appellant [The French text reads: “le projet tire par l'appelant' — Translator] from the “sale” of his territory was deemed to be remuneration for services rendered by the appellant in the course of his employment, in accordance with subsections 5(1) and 6(3) of the Act. [1] At the beginning of the trial counsel for the respondent explained to the Court that notwithstanding the fact that her client relied on subsection 6(3) of the Act and that the entire amount of $15,000 should be added to Mr. ...

The argument that somehow York loaned to York Boutique may be a fiction but at the same time the losses and the obligations encountered by York Boutique (the dollar basis of the alleged ” loan") were recognized as the responsibility of York—nothing could be clearer than that York eventually made good, in the name of York Boutique, for these amounts, totalling $69,000. ...

Queen & 5th, McBride July/85 $32,500 $28,200 2. 2nd Ave. Valemount Nov./85 $38,900 $32,700 3. 2nd Ave. ...