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Whether, under subsection 15(1) of the of the Income Tax Act (the “ Act ”), a benefit was conferred by Billvest Ltd. ... I agree to sell all of my Class ‘B’ shares to Canadian Oxy for $2,112,477.00 payable as follows: $ 422,495.00 on closing in 1987, and $1,689,982.00 on or before January 31, 1988. ...

By Notification of Confirmation dated May 15, 1997, the Minister confirmed that the reassessment, not to allow the deduction for other employment expenses for the 1995 taxation year in the amount of $957.00, was made in accordance with the provisions of the Income Tax Act (the ‘ Act ’). 9. ... It states at the commencement thereof “Period covered: from September 1, 1997 to June 30, 1998”. 5 Paragraph 8(1)(g) of the Income Tax Act (“the Act ”) provides: 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: (g) where the taxpayer was an employee of a person whose principal business was passenger, goods, or passenger and goods transport and the duties of the employment required the taxpayer, regularly, (i) to travel, away from the municipality where the employer's establishment to which the taxpayer reported for work was located and away from the metropolitan area, if there is one, where it was located, on vehicles used by the employer to transport the goods or passengers, and (ii) while so away from that municipality and metropolitan area, to make disbursements for meals and lodging, amounts so disbursed by the taxpayer in the year to the extent that the taxpayer has not been reimbursed and is not entitled to be reimbursed in respect thereof. 6 The appellant alleges he reported for work in Picton and it is his home terminal. ...

.: 1 This appeal is in respect to the Appellant's 1990 taxation year. 2 In computing his income for the 1990 taxation year, the Appellant did not include in his income an amount of $70,000 pursuant to subsection 146(10) of the Income Tax Act (the “ Act ”). 3 The Minister of National Revenue (the “Minister”) reassessed the Appellant for the 1990 taxation year by Notice of Reassessment dated July 22, 1994 by including, inter alia, the $70,000 in income. ... The fair market value of the shares was established by negotiations between the Appellant and the company's president and were based on the future cash flows from management fees from the Sportsbeat Bars & Restaurants Limited Partnership and other locations. ...

.: 1 Jill Hardy has appealed her income tax assessments for the 1993, 1994 and 1995 taxation years on the basis that she is entitled to deduct, pursuant to paragraph 8(1)(c) of the Income Tax Act (“ Act ”), the amounts of $5,815, $6,189 and $6,868 respectively, as rent paid for accommodation in those years since she was, and is, “a regular minister of a religious denomination”, ministering to a parish or congregation (“cleric's residence deduction”). ... Graydon</strong>: I should like to have some clarification of resolution [] which has to do with computing the income for 1948 and subsequent taxation years for a member of the clergy or a religious order. ...

.: — It was agreed at the outset that the two matters would be heard at the same time and the evidence would be considered in each appeal where relevant. ... R.), [1987] 2 C.T.C. 183, 87 D.T.C. 5391 (F.C.T.D.); Ben Matthews & Associates Ltd. v. ... In Webster’s Ninth New Collegiate Dictionary, Thomas Allen & Son Limited, the word “benefit” includes the word “advantage”. ...

Sutherland & Co. In order to determine the value of these shares the relevant legislation required that net value of the assets of the company at the date of death be ascertained and in so doing an allowance was to be included for contingent liabilities as mentioned. ... If English law is different — as to which I express no opinion — the difference is probably more in terminology than in substance. ...

Baillie, of Anderson Baillie & Company, a law firm in Vancouver, discussing the tax treatment of the scheme. ... As stated above, the material provided to the investors included a letter from Anderson, Baillie & Company, which letter appeared to be an opinion as to the tax treatment of the scheme. ...

There are two issues under appeal: (a) Deductibility of $7,086.00 in 1991 and $34,729.00 in 1992 under subparagraph 20(1)(p)(ii) of the Income Tax Act (" Act "); (b) Deductibility of $20,100.00 in 1992 and $36,000.00 in 1993, being amounts which the Appellant pleaded were paid to Yuncorp Holdings Limited ("Yuncorp") for services in respect of the management of rental properties in which the Appellant had an interest. [2] Paragraph 20(1)(p) of the Act provides: 20. (1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer's income for a taxation year from a business or property, 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:... ...

The appellant somehow survived — in fact he is still there — but he was well aware that his position was precarious. 12 In November 1992, the meat supervisor for the entire Thrifty Foods chain came to Parksville and told the owners that they should try to make the meat department more profitable. ...

In support counsel for the appellant cited the following decisions: Front & Simcoe Ltd. v. ... Lagueux & Freres Inc., [1974] C.T.C. 687, 74 D.T.C. 6569 (F.C.T.D.); The Queen v. ...