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Partnership (the “ partnership”). From the reply assumptions, and Mr. ...

One of those amounts is an aggregate figure which includes ”... his investment tax credit at the end of the year...”. ...

In the case of King Meadow Farms Ltd. (” King”) 1982 and 1983 years were involved. ...

The provisions that are of application in the present case are sections 6, 7 and 8 of the Tax Review Board Rules (the “ Rules”). ...

& J. Hicklen. This loan was not written off by the appellant in his 1981 income tax either. ...

:—This is an application made by the respondent under section 9 of the Tax Court of Canada Rules of Practice and Procedure for the Award of Costs (Income Tax Act) (" Court Rules"). ...

. — If the return of a taxpayer's income for a taxation year has been made within 3 years from the end of the year, the Minister (a) may, on or after mailing the notice of assessment for the year, refund without application therefor, any overpayment for the year, and (b) shall, with all due dispatch, make such a refund after mailing the notice of assessment if application therefor has been made in writing by the taxpayer within (i) the 6 year period referred to in paragraph 152(4)(b), where that paragraph applies, and (ii) the 3 year period referred to in paragraph 152(4)(c), in any other case. ...

What was said by Dickson, C.J. in the extract cited above was that ‘’... the taxpayer must satisfy the Court that his or her bona fide purpose in using the funds was to earn income”. ...

The notice of assessment issue reads as follows: Revenue Canada Revenu Canada NOTICE OF ASSESSMENT Taxation Impôt AVIS DE COTISATION 10569 DATE OF MAILING — DISTRICT TAXATION OFFICE DATE DE MISE A LA POSTE BUREAU DE DISTRICT D'IMPÔT May 22, 1990 TORONTO See Reverse for Inquiry Details Your Remittance for the Total Amount Assessed Should be Forwarded with the Attached Milton Wallace Remittance Form (Part 2) 533 College Street Retain Top Portion (Part 1). ...

. $1.60 x 82,500 = $132,000) all pursuant to paragraph 7(1)(a) of the Act. ...