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The appellant called as witnesses Isobel McNab, President of the Saskatchewan Treaty Indian Women's Council (hereinafter called the “ council”); Edith Dreaver, Executive Director of the council; Elizabeth Pratt, a secretary at the council and herself. ...

First, the introductory part of subsection 224(1.2) clearly indicates that Parliament intended to confer on the Minister of National Revenue the right to compel a person who owed money to a tax debtor or to a secured creditor to pay the money to the Receiver General of Canada, ” notwithstanding any other provision of this Act, the Bankruptcy Act, any other enactment of Canada, any enactment of a province or any law”. ...

His current financial records in relation to the horse operation with the use of the cash method and cost inclusion of new inventory in the year of purchase as expended show a clear direction towards profit: Summary of Horse Racing Activity and Horse Purchases, 1985 to 1990 Gross Revenue Total Expenses Net Loss Purchases' 1985 $26,321 $67,276 $40,955 $30,992 1986 38,458 60,735 22,277 18,340 1987 35,141 54,005 18,864 18,564 1988 27,582 32,681 5,099 — 1989 53,978 56,478 2,500 16,856 1990 66,967 69,944 2,977 12,000 NOTE: ...

On this point, I accept the evidence of Jeffrey Schrier of the accounting firm of Friedman & Friedman, whose services had been retained by the appellant in 1983. ...

In that case as in the case at bar (at page 341 (D.T.C. 5157)): ”... the plaintiff said that he just took it for granted that they were partners but never discussed it very much". ...

Zaldin relied upon the decision of this Court in /. Stollar Construction Ltd. v. ...

Bertucci was assessed for the unremitted source deductions for the period from April to July 1985 and for August 1985 (see Exhibit I-5 — notice of assessment No. 537691), while Mr. ...

., [1969] C.T.C. 581; 69 D.T.C. 5385, Kerr, J. of the Exchequer Court of Canada stated at 594 (D.T.C. 5392-93): Coming now to consideration of the question of the character of the transaction or arrangements by which the payments in question were made, it is well settled that in considering whether a particular transaction brings a party within the terms of the Income Tax Act its substance rather than its form is to be regarded, and also that the intention with which a transaction is entered into is an important matter under the Act and the whole sum of the relevant circumstances must be taken into account. [...] ...

On November 30, 1987, Reliance entered into an agreement with the bank wherein Coopers & Lybrand were appointed as a monitor. ...

Estimated and actual expenses before interest expense and capital cost allowance for the remaining years were as follows: Year Estimated Actual Actual 1984 $4,790 $ 8,521 1985 5,276 9,339 1986 5,800 8,430 1987 6,376 6,324 1988 7,013 11,705 1989 7,714 6,846 The purchase price for the unit was $175,000 of which $126,000 was financed by way of mortgages. ...