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I would also note that it is a well-established practice in tax law to look behind the form of an agreement to determine its substance: see Front & Simcoe v. ...

The expense was incurred for the purpose of producing an income-earning facility — the 72-room addition. ...

.: — The Plaintiff herein filed a Statement of Claim in which he appealed Notice of Reassessment No. 1911903, dated July 13, 1989 (the “Second Reassessment”) in respect of his 1981 taxation year. ...

It is noteworthy that the first line of text in the Notice states that “... it is expedient to amend the Income Tax Act and to provide among other things...” ...

Holmested & Watson, in Ontario Civil Procedure note in their commentary on Rule 31.06(1), which, as noted above, also uses the phrase “relating to”: While clearly irrelevant matters may not be inquired into, relevancy must be determined by the pleadings construed with fair latitude. ...

The plaintiffs received the following amounts as benefits under the plans: 1986 1987 1988 Dagenais $4,297.32 $10,166.28 $18,487.30 Halwachs N/A $13,852.72 N/A York N/A $ 2,092.80 N/A Paragraphs 6(1)(a) and 6(1)(f) of the Income Tax Act are the relevant statutory provisions in this appeal. ...

Valeo, supra, at p. 669 ”... every appropriation made by Congress uses public money in a manner to which some taxpayers object”. ...

S & S Properties Limited v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294 at 419 [6298] where Walsh, J in quoting from Roy M Powers Her Majesty the Queen, [1975] CTC 580; 75 DTC 5388 and the judgment of Addy, J therein states: Yet, one cannot say that, as a matter of law, every land developer is precluded from establishing that in a particular case there was no primary or secondary intention to speculate anymore than in a case such as the one at Bar where a mature man has never previously resold a piece of real estate at a profit, is one precluded from finding that, on his very first venture in this sphere, he did in fact have the intention of reselling at a profit when he originally purchased the lands. ...

Michael’s carried with it an appointment to the University — Dr. Marotta became a lecturer. ...

Coopers & Lybrand Limited, supra, at page 6547, as follows: In Crown Tire, Strayer was required to construe the phrase as it is used in paragraph 125.1(3)(a) of the Act. ...