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When determining if a taxpayer has a “ reasonable expectation of profit” one must place some emphasis on the word reasonable”. ...

The cephalometric diagnostic program being developed was in Queen's words ”... totally innovative in that there was no other such program on the market. ...

In the French language version of the statute, the corresponding word is “ principaux”. ...

.: — This is an appeal from an assessment of income tax made by the Minister of National Revenue (the “Minister”) on April 11, 1994 with respect to the appellant’s 1992 taxation year. ...

Under this agreement of purchase and sale the partnership agreed to pay the purchase price of $13,500,000 to Salloum Doak, Barristers & Solicitors, in trust, to be disbursed to the Bank of Montreal, the appellant’s creditor prior to the partnership, when clear title to the Capri assets was registered in the name of the partnership. 10. ...

.: — The Appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) for his 1988 and 1989 taxation years whereby the Minister added to his income, pursuant to subsection 15(1) of the Income Tax Act (the “Act”), the amounts of $374,000 for 1988 and $445,675 for 1989 as a shareholder’s benefit from Fobasco Limited (“Fobasco”) with respect to the use by the Appellant of a Florida condominium owned by Fobasco. ...

.: — Before commencing with the evidence counsel for the Appellant made a motion for the change of name of the Appellant from Guerette to Barnard as she had married since the filing of the Notice of Appeal. ...

However, as it has often been said in tax cases- although usually where the taxpayer was trying to qualify for a tax benefit and not, as here, where the taxpayer is trying to avoid an adverse tax consequence — that bookkeeping entries do not create reality. ...

Thill & Associates Inc. ("Thill") from Applied Research Ltd. ...

It is agreed that all profits earned by NETWORK will be allocated as follows: (a) Zero to $120,000 to Healy Holdings (b) $120,001 and over — 50 per cent to Healy Holdings and 50 per cent to Weber Holdings. ...