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As was stated in Evidence in Civil Cases, Sopinka and Lederman, Butterworth & Co. ...

The corporation Taillefer also benefitted from the non-payment of the sum of $21,000 that a related corporation by the name of Taillefer & Associés Incorporée could have required in respect of rent for the use of their premises by the corporation Taillefer during 1987. ...

[1] (j) the appellant was required to pay instalments of tax in respect of the 1987 taxation year on March 31, June 30, September 30, and October 30, each in the amount of $1,955.85; (k) the appellant was required to pay instalments of tax in respect of the 1988 taxation year on March 31, June 30, September 30, and October 30, each in the amount of $2,874.59; (l) during 1987, the appellant did not pay any instalments of tax in respect of the 1987 taxation year; (m) during 1988, the appellant paid instalments of tax in respect of the 1988 taxation year as follows: February 9,1988 $ 499.78 June 2, 1988 $1,000.00 July 5, 1988 $1,000.00 (n) the appellant has not paid the balance of tax assessed as payable in respect of the 1987 taxation year as at December 31, 1991; (o) the appellant has not paid the balance of tax assessed as payable in respect of the 1988 taxation year as at December 31, 1991; (p) instalment interest in respect of deficient instalments for the 1987 taxation year amounts to $446.87, as calculated in Schedule "A" attached hereto; (q) instalment interest in respect of deficient instalments for the 1988 taxation year amounts to $581.60, as calculated in Schedule "B" attached hereto; (r) the appellant’s chief source of income for both the 1987 and 1988 taxation years was neither farming nor fishing. ...

., Volume 37, London: Butterworth & Co. Ltd., 1982 at page 318 states that, On the other hand, it is not permissible, on an application to strike out the statement of claim, to try the action on affidavits when the facts and issues are in dispute in order to see whether the plaintiff really has a cause of action. ...

Subsection 56(12) reads: 56(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. ...

.: — It was agreed at the commencement of the hearing that these cases would proceed on common evidence. ...

Ouellette & Brett (supra). Later, he concluded as follows at page 2054 (D.T.C. 354): Accordingly, I find that the point at issue, as in In re Spiral et al. v. ...

The difference was explained in the following terms: [TRANSLATION] Q. [...] ...

., in conformity with Stubart, was careful to qualify the importance of a bona fide business purpose by stating that, although it "... is not determinative of the artificiality of the deduction”, it “is certainly relevant”. ...

. … The words “prevent” and “prévenir” mean the same: to stop an event from happening before it happens. ...