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The Minister by reassessment has included in computing each of the appellants' income for the 1988 taxation year an amount as follows: Proceeds $7,630,000 Cost of Sale (6,000,000) Selling Expenses ($124,000) Gain on Sale $1,505,206 Less: Reserve (109,602) Total Gain in Year $1,395,604 [Each] Appellant's Share (25 per cent) $ 348,900 Previously Included in Income as Taxable Capital Gain 232,600 Additional Income Assessed $116,300 In 1988, a 74.5 acre parcel of land adjacent to the subject property was acquired by Araz Developments (owned by Ara Boyajian) and Sebian Developments (owned by Sayouh Boyajian), in equal shares as tenants in common and this property is still held in the same ownership. ...

By letter (the “opinion letter") dated June 14, 1989 Thorne Ernst & Whinney delivered an opinion to the BCASI on the income tax implications of the BCASI making funds available to corporations such as the appellant for SRED purposes. ...

Rosales’ 1986 taxation year, dated October 26, 1989, inadvertently contained an erroneous reference to “ Hutee Hydraulic Product" which has no relevance to the assessment of that taxation year. ...

It is not clear to me how the amount of $51,949 was determined because, as I read the judgment and the pleadings herein, the only payments made to Constance in 1985 were as follows: January, February and March @ $3,789.84 $11,369.52 Single Payment April 1, 1985 33,800.00 Total $45,169.52 The respondent has not disputed the quantum of the amount of $51,949 and so the only issue is whether the appellant is entitled to deduct in computing income for 1984 and 1985 the amounts of $45,478 and $51,949 respectively. ...

& Yukon Chamber of Mines report of January 31, 1971 indicated that ecological studies and water tests had already been conducted) and various news releases were indicating a much earlier date for contracted production (for example, Metal News, July 24, 1971, had reported plans for two million tons from "around 1973" and had outlined Japanese participation). ...

Section 54 and 132 of the Tax Court Rules — General Procedure, read as follows: 54. ...

., as he then was, stated at page 486 (C.T.C. 314, D.T.C. 5215-16): Whether a source of income is a taxpayer's “ chief source” of income is both a relative and objective test. ...

Appellant's counsel submitted ”... that should probably have been done by way of a salary from the company. ...

The word “ payable” is defined as"... that may, can or must be paid" (Webster's Ninth New Collegiate Dictionary, 1989, at page 864), and as: Capable of being paid; suitable to be paid; admitting or demanding payment; justly due; legally enforceable. ...

.:— On November 19, 1987, a notice of assessment was issued to the appellant in his capacity as a director of Lincoln Pub Ltd. (” Lincoln Pub”) with respect to unremitted source deductions owing when Lincoln Pub went out of business in September, 1986. ...