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Minister of Manpower & Immigration, [1978] 2 S.C.R. 375, 81 D.L.R. (3d) 687, at page 381 (D.L.R. 691). ...

Therefore, the maximum amount that could be assessed against the Appellant was $20,912 calculated as follows: Amount assessed under section 160 $52,662.30 Estimated value of the Appellant's shares according to evidence between $58,000 to $69,000 say    $63,500.00 One-half thereof to Mrs. ...

In 1994- according to Records of Employment – Exhibits R-4 and R-5- she worked 14 weeks for Doreen McMillan and 8 and 2/3 weeks for Almey. ...

At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: “... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”. ...

David Pilkington, a chartered accountant and partner of Hudson & Company, Karon’s accountants, prepared a letter for Kondrat’s solicitor suggesting the shares of Karon in June 1985 "would be worth a value anywhere from $0 indicating the seismic data was worthless and the future earnings potential of the company is not very favourable to a value far exceeding the cost of the seismic data indicating that the seismic data is extremely valuable". ...

., General Signal and Appliances Ltd. and Black & Decker Ltd. accounted for federal sales tax on small electrical appliances based on such determined values, which were requested by the above-mentioned companies and were authorized by Excise. ...

.* 256 common Adrien Allard * Chipik Investment Ltd. and Allard Ventures Ltd. became shareholders in July 1976. ...

London & West Riding Investments Ltd., [1967] 1 All E.R. 518, [1967] 2 Q.B. 786 (C.A.) at page 528 (Q.B. 802):.... which are intended by them to give to third parties or to the Court the appearance of creating between the parties legal rights and obligations different from the actual legal rights and obligations (if any) which the parties intend to create. ...

Counsel for the respondent contended that the application of subsection 56(2) of the Act is supported by the following facts: (a) the dividend payment was not the product of a bona fide business relationship” (judgment of Dickson, C.J.C. at page 35), but was conceived as part of a tax avoidance plan; (b) the dividend payment was, in effect, a rerouting of monies from New- mac, in which the appellant's wife had no claim or entitlement, that would otherwise have been payable to the appellant; (c) the declaration of a dividend, although normally the function of a director, in this case was the fruit of the appellant's recommendations to his wife; (d) the declaration of the dividend to the appellant's wife from Melru was merely a temporary device for the redirection of the dividend, as the money was immediately lent back to the appellant by his wife on non-commercial terms; and (e) ”... there was no legitimate purpose to the dividend distribution” (judgment of Dickson, C.J. at page 35), within the meaning of the majority judgment in McClurg. ...

The Statute The relevant provisions of the Income Tax Act are found in Part I, Division I — Returns, Assessments, Payment and Appeals. ...