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The first case relied upon by the defendant is the Supreme Court of Canada decision in James Richardson & Sons Ltd. v. ...

Relevant Staturory Provisions Income Tax Act, S.C. 1970-71-72, c. 63 (applicable to taxation years 1985 and 1986) 18.(1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (b) an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part; 20.(1) Notwithstanding paragraphs 18(l)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (¢) an amount paid in the year or payable in respect of the year (depending upon the method regularly followed by the taxpayer in computing his income), pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than borrowed money used to acquire property the income from which would be exempt or to acquire a life insurance policy), 38. ...

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. ...

Fisher would from time to time receive from various insurance companies what were known as contingent commissions — a type of performance bonus given to an agent if he performs well as an underwriter. ...

At page 613 (D.L.R. 498), Lamer, J. stated that the 26 months to trial “was, though lengthy,... not in violation of the accused's rights under paragraph 11(b) given ‘the time requirements inherent in the nature of the case' ”. ...

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. ...

Marsh & McLennan, Ltd., [1984] F.C. 609; [1983] C.T.C. 231; 83 D.T.C. 5180 at 244 (D.T.C. 5191; F.C. 627), Clément, D.J.; Golden v. ...

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