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As Robertson J.A. stated: "CNR did more than save [the taxpayer’s] pocket — it put money in it" (page 393 (D.T.C. 6185)). ... Had the appellant not moved from, and sold, his Richmond residence he would today — and in 1991 — own an asset which appreciated considerably. ...

Carew each owned a 50 per cent interest in a partnership called A & A Enterprises. ... From 1983 to 1985 Tourism produced the following income: Taxation Gross Net Income Appellant's Year Income Expenses (Loss) Snare are 1983 $1,715 $28,357.18 ($26,642.18) $13,321.09 1984 $2,250 $29,643.42 ($27,393.42) $13,696.71 1985 $2,700 $21,598.08 ($18,898.08) $ 9,449.04 The appellant, in his returns of income for the years in issue, sought to deduct these losses as expenses incurred for the purpose of producing income. ... The Minister of National Revenue (the Minister) disallowed the losses claimed by the appellant with respect to tourism as well as 50 per cent of the additional expenses claimed which related to tourism as follows: Tourist 50% of Additional Total Loss Year Activity Loss Expenses Disallowed 1983 $13,321 $1,844 $15,165 1984 $13,696 $2,376 $16,072 1985 $ 9,449 $4,647 $14,096 The disallowance was based on the Minister’s assumption that the appellant did not have a reasonable expectation of profit from tourism during the taxation years in issue. ...

The money held back as a guarantee of the execution of the work shall be released as follows and at the moments described below: — $50,000 plus interest earned from the time the elements of the monument are ready to be swung onto the ring linking them; — $100,000 plus interest earned from the moment the structure is ready to receive the dome; — $150,000 plus interest earned at the end of the work. ...

Jérémie Dauphinais’ intention was to defer this loss as follows: 1977 $28,581 1980 $19,762 1981 $ 5,294 3. ... Having regard to the nature of the proposals put forward by counsel for the appellant which the latter would acknowledge — if the premise were taken for granted that the loss was created in 1978 — 1 would even be inclined to believe that this loss was deductible in 1977. ...

And from the way in which both appellants described Jacinto and his needs, I conclude that he was in desperate need of the three necessities of life — food, shelter and clothing. ... If I add the two amounts which were added to the reported 1986 incomes of the appellants — $12,357 for Rita and $800 for Francisco — I find that, in 1986, the sum of those amounts, $13,157, was in fact paid by the company to Jacinto Bettencourt without any source deductions. ...

They read as follows: 8(1) In computing a taxpayer's income for a taxation year from an office or employment, 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: (m) the amount in respect of contributions to registered pension plans that, by reason of subsection 147.2(4), is deductible in computing the taxpayer's income for the year; 147.2(4) There may be deducted in computing the income of an individual for a taxation year ending after 1990 an amount equal to the aggregate of (a) the aggregate of all amounts each of which is a contribution (other than a prescribed contribution) made by the individual in the year to a registered pension plan in respect of a period after 1989, to the extent that the contribution was made in accordance with the plan as registered, (b) the least of (i) the amount, if any, by which (A) the aggregate of all amounts each of which is a contribution (other than an additional voluntary contribution or a prescribed contribution) made by the individual in the year or a preceding taxation year and after 1945 to a registered pension plan in respect of a particular year before 1990, if all or any part of the particular year is included in the individual's eligible service under the plan and if (1) in the case of a contribution that the individual made before March 28, 1988 or was obliged to make under the terms of an agreement in writing entered into before March 28, 1988, the individual was not a contributor to the plan in the particular year, or (II) in any other case, the individual was not a contributor to any registered pension plan in the particular year exceeds (B) the aggregate of all amounts each of which is an amount deducted, in computing the individual’s income for a preceding taxation year, in respect of contributions included in the aggregate determined in respect of the individual for the year under clause (A), (ii) $3,500, and (iii) the amount determine by the formula ($3,500 x Y) — Z where Y is the number of calendar years before 1990 each of which is a year (A) all or any part of which is included in the individual's eligible service under a registered pension plan to which the individual has made a contribution that is included in the aggregate determined under clause (i)(A) and in which the individual was not a contributor to any registered pension plan, or (B) all or any part of which is included in the individual's eligible service under a registered pension plan to which the individual has made a contribution (I) that is included in the aggregate determined under clause (i)(A), (Il) that the individual made before March 28, 1988 or was obliged to make under the terms of an agreement in writing entered into before March 28, 1988, and in which the individual was not a contributor to the plan, and Z is the aggregate of all amounts each of which is an amount deducted, in computing the individual’s income for a preceding taxation year, (A) in respect of contributions included in the aggregate determined in respect of the individual for the year under clause (i)(A), or (B) under subparagraph 8(1)(m)(ii) (as it read in its application to the 1990 taxation year) in respect of additional voluntary contributions made in respect of a year that satisfies the conditions in the description of Y, and (c) the lesser of (i) the amount, if any, by which (A) the aggregate of all amounts each of which is a contribution (other than an additional voluntary contribution, a prescribed contribution ora contribution included in the aggregate determined in respect of the individual for the year under clause (b)(i)(A)) made by the individual in the year or a preceding taxation year and after 1962 to a registered pension plan in respect of a particular year before 1990 that is included, in whole or in part, in the individual's eligible service under the plan exceeds (B) the aggregate of all amounts each of which is an amount deducted, in computing the individual’s income for a preceding taxation year, in respect of contributions included in the aggregate determined in respect of the individual for the year under clause (A), and (ii) the amount, if any, by which $3,500 exceeds the aggregate of the amounts deducted by reason of paragraphs (a) and (b) in computing the individual’s income for the year. 32. ... Accordingly, A.V.C.s are excluded from the ambit of the rules in paragraph 147.2(4)(b) and (c) concerning service before 1990 — ie they are not deductible thereunder. ... Meany entitled, “ Income Tax Rules Affecting Pensions and Pension Plans”, in Pensions: Advising Clients in a Changing Environment, The Law Society of Upper Canada, Department of Continuing Education (Oct., 1991). ...

In assessing the appellant for his 1984 taxation year the respondent relied, inter alia, on the following facts: (a) the company" Restaurant les Promenades du Centre-ville Inc.” was incorporated on July 6, 1983; [admitted] (b) the operations of “ Restaurant les Promenades du Centre-ville Inc.” began on June 21, 1984 and ended in bankruptcy on November 15, 1984; [admitted] (c) "Restaurant les Promenades du Centre-ville Inc.” operated the restaurants “Café Bonaparte", at 680 Grande-Allée, Québec, and "Les Jardins du Luxembourg" and a cafeteria, located at 540 Charest Boulevard East, Québec; [admitted] (d) Robert Glode and Marc Philippe Weiller operated this company using a nominee, Mr. ... Law — case law — analysis 4.01 Law The principal provisions of the Income Tax Act involved in the instant case are paragraph 15(1)(b) and subsections 152(7), 162(1) and 163(1). ...

He contended that the fact that he had personally signed the two contracts at the centre of the present proceeding, the subject of which was the television series ” L'Or du Temps", was ultimately only the result of an error or an informality. ... The Queen, [1987] 1 S.C.R. 32, [1987] 1 C.T.C. 117, 87 D.T.C. 5059, reiterating the same principle in the following terms, at pages 54 and 55 (C.T.C. 129, D.T.C. 5067-68): It was submitted — and the Crown generously conceded — that the Trust would have obtained an interest deduction if it had sold assets to make the capital allocation and borrowed to replace them. ...

:—The appellant purchased a residential unit (the''unit") and in January of 1988 sold the unit and made a profit of $47,292 (the ” profit"). ... In addition, the Minister levied penalties (the " penalties”) under subsection 163(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Each of the verbs in the language “ participated in, assented to or acquiesced in” connotes an element of knowledge on the part of the principal and that there must be concurrence of the principal's will to the act or omission of his agent, or a tacit and silent concurrence therein. ...

(b) Queenswood and Ten Mile Point 0.5 acres — (c) Areas liable to flood 5.0 acres — (4) In the remainder of the Municipality the minimum lot size shall be 8,400 sq. ft. and the minimum width 70'0". ... O'Reilly & Bélanger Ltd. v. M.N.R., [1917-27] C.T.C. 332; 1 D.T.C. 121; 12. ...