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Minister of National Revenue, [6] Heald J. stated:...I conclude that the words employed by Parliament in paragraph 60(b) must be interpreted "... in their ordinary grammatical sense”. ... & S. 259, 1 L.J.C.P. 73, 8 Bing. 179 (Eng. C.P.) (January 23, 1832); Barchak Estate v. ...

., for the Federal Court of Appeal, stated at page 6264: [...] the general principle defining an “allowance” for purposes of paragraph 6(1)(b) is composed of three elements. ... C.A.) at 6176: [...] Even when these amounts are not used for any improper purpose, and even when they are reasonable estimations of the costs, our law treats them as additional remuneration, not as reimbursement of expenses, which require detailed receipts being submitted for reimbursement. ...

In so reassessing the Appellant, the Minister made the following assumptions of fact: a) The facts admitted above; b) The Appellant is a corporation incorporated pursuant to the laws of the Province of Saskatchewan and is engaged in a farming operation near Melfort, Saskatchewan; c) The Appellant’s taxation year ends on December 31; d) Lloyd James Taylor and Mary Jean Taylor are the sole directors and shareholders of the Appellant; e) On November 4, 1993, Lloyd Taylor entered into a “Contract for the Sale of a New Farm Implement — Form A” (the “Contract”) with Farm World for the purchase of the Farm Machinery; f) The Farm Machinery was to be delivered, according to the Contract, by December 31, 1993; g) Farm World is a dealership handling new and used farm equipment in the Province of Saskatchewan: h) Farm World ordered the Farm Machinery on November 4, 1993 from the manufacturer, Ford New Holland Canada Ltd.: 1) The manufacture of the Farm Machinery was completed on February 7, 1994: j) The Farm Machinery was shipped from the manufacturer to Farm World on February 14, 1994; k) The Farm Machinery was delivered to the Appellant on April 15, 1994; l) The retail date for warranty purposes was recorded by the manufacturer as March 18, 1994; m) As part of the consideration for the sale, the Appellant traded in a John Deere 8960 tractor (the “Trade-in”); n) The Trade-in was received by Farm World on November 30, 1993; o) The balance owing under the Contract was $18,000.00 which was paid by the Appellant by a cheque dated December 31, 1993; p) In the 1993 taxation year, the Appellant did not acquire, obtain title to nor have all of the incidents of ownership such as possession, use and risk of the Farm Machinery; q) The Farm Machinery was not in existence, produced, nor in a deliverable state as at December 31, 1993; and r) In reporting income for its 1993 taxation year the Appellant: 1) claimed Investment Tax Credits in the amount of $17,570.00 to which it was not entitled; and ii) under-reported the amount of recapture of depreciation by $175,454.00. ... On November 4, 1993, Lloyd Taylor, on behalf of the Appellant, entered into a “Contract for the Sale of a New Farm Implement — Form A” (the “Contract”), which is Document #3 in this Request to Admit, with Farm World Equipment Ltd. ...

Jurisprudence 10 The Income Tax Act (the “ Act ”) does not define “business”, but merely stipulates that a “business” includes a profession, calling, trade, manufacture, undertaking of any kind whatever. ...

(b) from four rural municipalities for Class E shares by October 31, 1991 — $181,000. (c) from one rural municipality as a loan — $80,000. (The exhibits indicate that the actual amount in (b) above should be $125,557). 6 Denis testified that he has invested $50,000 in W.E.P.L. ...

Therefore, because of subsection 1100(15) of the Income Tax Act Regulations (“ Regulations ”), the Appellant was not entitled to deductions for the capital cost allowances since they increased losses. 8 The Appellant submits firstly that because he purchased the yacht in 1985 he is not subject to the restrictions in subsection 1100(15). ...

It is an appeal from an assessment with respect to the appellant's 1995 taxation year whereby the Minister of National Revenue (the “Minister”) found him liable for instalment interest of $231.30 and interest arrears of $2.16 pursuant to subsection 161(2) of the Income Tax Act (the “ Act ”). 2 In assessing the appellant, the Minister made the assumptions of fact stated in paragraphs 4a) to h) of the Reply to the Notice of Appeal which read: a) during the 1995 taxation year, the Appellant's total income was $178,666; b) during the 1995 taxation year, the Appellant did not earn any income from fishing or farming; c) during the 1995 taxation year, the Appellant's income from which amounts were deducted at source was $93,045; d) the Appellant's net tax owing for the 1995 taxation year was $11,493.90; e) the Appellant's net tax owing for the 1993 and 1994 taxation years were $32,786.85 and $14,341.66 respectively; f) on January 7th, 1995, the Appellant was informed that his provisional account payable based on the 1993 taxation year was $32,786.85 which consisted of payments of $8,196.71 payable on the 15th of March and June 1995. g) on July 8th, 1995 the Appellant was advised that his provisional account payable based on the 1994 taxation year was $14,341 which consisted of quarterly payments of $3,585 on the 15th of March, June, September and December 1995; h) the Appellant instead chose to pay instalments as follows: in March 1995 $1,767.00 in June 1995 2,032.00 in September 1995 3,031.00 in December 1995 2,277.00 $9,107.00 3 The appellant does not challenge these assumptions except for paragraph 4g) as he does not know whether or not he was so advised. 4 Instead, relying on the decision of this Court in Paquette [FN1: <p><em>Paquette c. ...

Furthermore, the law firm, the partnership, Waterbury, Newton & Johnson, is not now and never has been a shareholder of Webster Field Holdings Limited, that they're separate and distinct. ... To the foregoing he added: The law firm Waterbury, Newton & Johnson, I became a partner in the year 1969. ...

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. ...

.: 1 These appeals are from net worth assessments made under the Income Tax Act (the “ Act ”) for the Appellant's 1989, 1990 and 1991 taxation years. ...