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The appellant also filed a certificate of incorporation to show that a company was incorporated on May 25, 1970 under the name of Varga Art & Frames Shop Ltd. ... However, the business was never transferred to the company and the appellant and his wife advanced more than $3,250 to the business, viz $5,000 according to Exhibit A-1, Tab 4, detailed as follows: $ 300.00 Our statement of account May 12th, paid out to Varga Art & Frames Shop which said cheque was given to Vargas and Wayne Rudolph to take to 3,250.00 the Bank of Nova Scotia to pay out a loan of the Vargas June 12th, paid to Varga Art & Frames Shop to deposit at 1,450.00 Bank on the instructions of Wayne Rudolph $5,000.00 According to this exhibit, it appears that the $5,000 was distributed by the solicitor who handled the incorporation of the company. ... The appellant testified that he never bought any paintings for his own use and enjoyment, and that the ones under discussion were acquired to be transferred to Varga Art & Frames Shop Ltd. ...

Had it been so directed — despite the fact that the appellant no longer lived at the residential address or carried on business at the business address — and even despite the fact that the assessor was aware of these facts — it might well be that in the absence of any act on the part of the appellant to notify the Minister of a change of address, he would be bound by the sending of a notice to either of the addresses so given. ...

Development, or price appreciation — not investment — was the primary and sole motivation behind the purchase of the Tyndall and Inkster properties. ...

Also the American parent company, Webb & Knapp Inc of New York, was in trouble, which reflected seriously on the credit of the Canadian company. ... In the administration of their affairs, Webb & Knapp (Canada) Ltd treated all real estate holdings as inventory, and all sales of buildings and real estate were reported as income items. ... Firstly, it acted as a conduit pipe for the levelling of profits, and second, it functioned as a manager under an arrangement with its parent company, Webb & Knapp (Canada) Ltd. ...

The said application for an extension contains the following facts which, in my view, summarize the problem: — On March 5, 1979 the respondent assessed the applicant for the 1976 taxation year in the notice of assessment bearing No 410802; — On May 31, 1979, the applicant filed a notice of objection against the above- mentioned notice of assessment; — On August 19, 1980 the respondent issued by registered mail a Notification of Confirmation by the Minister relating to the above-mentioned notice of assessment; — The applicant did not learn of the sending of this Notification of Confirmation by the Minister until early October 1981; — Since she did not know of the sending of the said Notification of Confirmation by the Minister until early October 1981, the applicant could not institute an appeal to the Court within the prescribed time, namely, within ninety days from the date of mailing of the said Notification; — The Notification of Confirmation by the Minister was not sent to the applicant personally but rather to her accountant with a copy to her lawyer; — The applicant has lived in France since early 1979. ... Counsel for the applicant filed the following documents: — A letter dated July 7, 1980 from Revenue Canada to the applicant addressed to “Côte St Catherine Road”, which related directly to the notice of objection involved in this application; — A receipt from Revenue Canada dated July 15,1980 sent to the applicant at the address on Henri Bourassa in part payment of the tax payable. ... The tax form she used was the current form with the previous address preprinted thereon and sent to her by Revenue Canada. † The change of address from Côte des Neiges to Henri Bourassa did not appear on the forms sent by Revenue Canada for 1978 and 1979. ...

Here are the names of the companies with the value of the shares and the amounts of the loans: Value of Shares Loans Ste-Dorothée Dev Corp $37,918.00 $ 1,276.00 Key Acceptance Corp 14,212.00 2,862.00 Guard Development Corp 5,456.00 2,066.06 Manhattan Development Corp 11,900.00 18,612.44 Wentworth Development Corp 27,600.00 39,548.64 Fides Development — 1,773.34 Civic Land Development Corp 13,414.00 2,933.36 Twin Development Corp 20,126.00 60.00 Wentworth Corp 10,012.00 Newtrend Dev Corp 17,980.00 Colony Dev Corp 50,046.00 Forward Dev Corp 7,864.00 Broadway Construction Co 73,250.00 Ultra Development Corp 9,552.00 Wentworth Dev (Ont) Ltd 1,001.00 Metra Investment Ltd 3,850.00 Salada Foods Ltd (Ont) 150.00 TOTAL $304,331.00 69,132.50 As to the first liability of $84,628, the following documents were filed: (1) Exhibit A-6 — A document dated May 7, 1954 and signed by Louis Zbarsky and Louis and Sam Landsman showing that they were jointly and severally responsible for the said debt of $253,888.73 to the Bank of Montreal. (2) Exhibit A-7 — Judgment No 796524 of the Quebec Superior Court dated June 7, 1971, showing that Louis Zbarsky, Louis Landsman and the late Sam Landsman had to pay the sum of $253,888.73. As the second liability of $51,605.89, the following documents were filed: (1) Exhibit A-3 — Judgment No 759186 by Mr Justice Challies. (2) Exhibit A-8 — Confirmation by the Bank of Montreal to the effect that the Estate was indebted to the Bank for the amount of $51,605.89 as of Feb 2, 1968. ...

He was not a designated parish priest. 3.02 During that year, however, he was professor and student chaplain at the St Lawrence College in Cornwall, Ontario, and at SD & G County Board of Education, Cornwall, Ontario. 3.03 He received $2,435.07 from SD & G County Board of Education and $9,988.70 from St Lawrence College. 3.04 The salary he received from St Lawrence College was only as a teacher and not as student chaplain. ...

. — Desjardins began performance of the subcontract in early February 1976, with 20 and 25 employees. ... The amounts of all such cheques were stipulated to the taxpayer by Desjardins’ accountants Guimond Faucher & Cie, who at all relevant times acted solely for Desjardins to the exclusion of the taxpayer. ... In reviewing that question, the significant evidence as I see it is: — “R” made out cheques to the employees, and included thereon the name of “D”. ...

These fees are broken down as follows: 1971 $2,870.00 1972 $7,546.20 1973 $3,595.00 1974 $4,899.31 Claims The appellant’s position is the following: — It operates a pharmacy in the City of Berthierville, Province of Quebec, under the name Produits Guy Barrette Inc; — It used the services of a specialized agency which does business under the name of the Association professionelle des Pharmaciens salariés du Québec and provides various pharmacies with staff when needed; — It usually made out a negotiable cheque in advance, which could be readily converted into cash to pay the replacement pharmacist the fees owed to him for his day’s work. The respondent’s position is the following: — Under the above-mentioned section of the two Pharmacy Acts, the appellant cannot employ pharmacists to operate the pharmacy. ...

The borrowers in the present appeals can only claim immunity from the provisions of paragraph 15(2)(b) under the provisions of paragraph 15(2)(a) of the Act — and that requires again that they be shareholders in addition to being “officers or servants”, and using the funds “to purchase a dwelling house”. ... The utilization of the company bank account was precisely for the purpose of respecting the provisions of paragraph 15(2)(a) of the Act — again one of those provisions is that he should be a shareholder. ... The only matter at issue, therefore, is whether there was a benefit conferred by the loan being granted “interest free” — since that aspect of the matter is not equally sheltered simply by virtue of subsection 15(2) of the Act. ...