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Bowman" A.C.J. [1]               In A.G. of Canada v. Mastri et al., 97 DTC 5420, the Federal Court of Appeal stated at page 5422 "... a decision of one panel of this court is not binding on another". ...

The other allegations of fact in paragraph 5 of the Reply to the Notice of Appeal which the appellant admitted or did not rebut — I am referring to subparagraphs (a), (c), (d), (e), (f) and (g) — are not sufficient grounds for the Minister of National Revenue's conclusion that a payer dealing at arm's length would not have hired the appellant under the terms and conditions that were established. [38] The Minister of National Revenue therefore exercised his discretion unlawfully. [39] I further conclude on the whole of the evidence that a substantially similar contract to the one before the Court could have been entered into by two persons dealing with each other at arm's length. ...

The Respondent called Lyle Faulkner, Tajinder Kooner and Donald Balanger, officers of Revenue Canada. [2] The Appellants were assessed pursuant to section 227.1 of the Income Tax Act (the " Act ") for their 1991 taxation years for liability as directors respecting unremitted withholdings by Art-Pac Marketing Communications Inc. ...

Larson pointed out to him that the children were not yet eighteen and that somebody was ”... supposed to be in charge to represent them until they are eighteen...”; that"... we decided to put my brother and the lawyer in control, whatever, but then she decided—we decided she [was] supposed to be the control of the company for the kids until they're eighteen years old”. ... & J. 264 at 274-75 Turner, L.J. stated: I take the law of this court to be well settled, that, in order to render a voluntary settlement valid and effectual, the settlor must have done everything which, according to the nature of the property comprised in the settlement, was necessary to be done in order to transfer the property and render the settlement binding upon him. ...

Subsection 227.1(3) refers to a director who has “ exercised the degree of care, diligence and skill to prevent the failure...”. ... If the “ failure” in subsection 227.1(3) is an isolated event, then the conduct of a director after that event would in most circumstances be irrelevant. ...

(" Forma corporation") to Brigden Credit Union. The appeals deal with the appellants relationship in 1983 and 1984 with two corporations of which he was a shareholder: Forma corporation and 494101 Ontario Ltd. ... There are debits and credits for 1982 shown but no explanation as to what they are, except that there was reference to “ Russell Street" with entries showing a $17,972.25 credit probably according to Mr. ...

The appellant filed a document entitled ” Reply to Respondent's Reply”. In it the appellant: (a) denied that the aircraft and other property were purchased for “ film making purposes”; it alleged facts which, generally speaking, tended to show acquisition for use in connection with the business of manufacturing and selling satellite television antenna systems; it pleaded that shortly after the purchase of the aircraft the market for such systems suffered a set back and that film making was then taken up as a stop gap to make use of an asset that would otherwise have been unused; (b) in relation to scientific research activities asserted that it had "provided sufficient documentation to qualify its activities to be bona fide undertakings"; (c) asserted that it maintained an office and storage facility at a country home known as the Hillsburgh property and used the property as a site for scientific research and development, a site for making industrial films to be used for the purpose of demonstrating the appellant's products and as the main business location of its president and owner; (d) claimed that snowmobiles and a piano were acquired for use by business guests at the Hillsburgh property and that a shelf unit had been acquired for use at trade shows; (e) claimed that the expenses of the Caribbean cruise taken by its owner and president related to the satellite business; (f) claimed that Visa charges in question were "made in bona fide company business pursuits". ...

S.C. 1970-71-72, c. 63) (the "Act"), the respondent issued reassessments to the appellant and added the following amounts to his reported income for the respective taxation years: 1984 $15,622 1985 $ 9,713 1986 $12,071 The respondent claims that the above amounts are benefits deemed to have been received by the appellant under subsection 80.4(2) with respect to loans received from or debts incurred to the company by virtue of his shareholding in the company. ... In the books and records of the company for the years under appeal, the following amounts are shown as liabilities for accrued management salaries and bonuses payable to the appellant or his wife: March 31, 1984 $ 7,000 March 31,1985 $195,000 March 31,1986 $147,032 On the company's balance sheet at each year end, the above amounts are not shown as an independent item but they are included as part of "Accounts payable and accrued liabilities". ...

.: — William J. Brown appeals from assessments of tax with respect to his 1989, 1990 and 1991 taxation years. ... In describing more fully the taxpayer who farms for his livelihood Dickson J. stated at pages 487-88 (C.T.C. 315; D.T.C. 5216) that for such individual, the farming “... may reasonably be expected to provide the bulk of income or the centre of work routine”. ...

.: — In this appeal, the parties have agreed that the appeals be allowed, the assessments vacated, and the matter is referred back to the Minister of National Revenue (the “Minister”) for reconsideration and reassessment on the basis that the Appellant has not made any misrepresentation attributable to neglect, carelessness, or wilful default, nor has he committed any fraud in filing his 1987 tax return and that consequently, the reassessments of the Appellant’s 1987 taxes, dated July 15, 1992 and May 5, 1993 are invalid as having been made beyond the normal three-year reassessment period provided for in subsections 152(3.1) and 152(4) of the Income Tax Act (the “Act”). ... Such a basis was disapproved of in the Reading & Bates case ((1986) 2 F.T.R. 241 at 264). ...