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In Lloyd Youngman & Company Inc., Trustee of the Estate of Harold Fraser in Bankruptcy v. ... Merson since the words of that provision offer relief to a director ”... where he exercised the degree of care, diligence and skill to prevent the failure that a reasonably prudent person would have exercised...”. ... He can say that he would have paid the deductions if the money had been available — in essence if the bank had allowed him more credit. ...

.: — The only point at issue in this appeal concerns the right of the appellant, TELECOMSYST SERVICES INC. ... You understood the form — it’s a new proposal- but you could not recognize that it no longer had anything to do with Republic; you did not know that it involved Stratacom; you did not know what technology was being referred to? ... Well, the project’s complexity was in finding technical and financial solutions so that — as was said, we had to offer a service that would cost TPG perhaps 50 per cent of what the telephone companies normally offered- so that substantial reductions could be offered to its suppliers so that they would want to switch from the existing service to the new service and, second, to ensure that there was enough room to manoeuvre in the price war that would follow so that we could remain a viable entity in the following years. ...

.), at 5045 in a different context, “... too fine a distinction for my liking.” ... The work of the parties who did not testify was described by very credible witnesses — Messrs. Churchman, Alemu, Sewell, Grimes and Sider — and their senior and responsible managerial functions are set out in their detailed job descriptions. ...

Coopers & Lybrand Ltd., [1980] C.T.C. 367, 80 D.T.C. 6281 (F.C.A.), case should be referred to and if there is any liability, it is only for failing to deduct, not failing to remit. ... In that case Coopers & Lybrand was appointed receiver and distributed cheques to workers equal to their net pay. ... In the Coopers case, Coopers & Lybrand as receiver, was given a certain sum of money which it utilized to pay wages without making any deductions. ...

She of course will give you one-halt of her Canada Pension (as adjusted — if she has one). 7. ... Nelson — albeit expressed in gentler language such as,"she desires" or "she wishes" — but requesting that he agree to those terms in a separation agreement. ...

.: — The appeal is from notices of reassessment for its 1987 and 1988 taxation years in which the Minister of National Revenue (“Minister”) denied the deduction of the penalty in the amount of $1,169,738 imposed on the Appellant pursuant to subsection 50(4) of the Excise Tax Act. ... In Day & Ross Ltd. v. R. (sub nom. Day & Ross Ltd. v. The Queen), [1976] C.T.C. 707, 76 D.T.C. 6433, the Court held that fines for trucks loaded above weight restrictions were deductible as a business expense. ...

Reasons for Judgment Lamarre, J.T.C.C. [1] This appeal, heard under the informal procedure, is from an assessment under Part IX of the Excise Tax Act (“ Act ”), the notice of which, dated January 1, 1994, bears number 05B2717 and covers the period from January 1, 1991 to December 31, 1991. ... Hamill (1810), 1 Ball & B. 377; Fisher and Lightwood, Law of Mortgages, 7th ed., p. 720. ...

.: — The appellants Eric Detchon and Clifford Goodwin appeal income tax assessments for the 1985 and 1986 taxation years on the basis neither of them received a benefit in respect of employment pursuant to paragraph 6(l)(a) of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ... Registrar of Probates, [1990] A.C. 323 at 335, quoted in Craies on Statute Law, 7th edition, London: Sweet & Maxwell 1971 at page 87: Where there are two meanings, each adequately satisfying the meaning (of a statute), and great harshness is produced by one of them, that has a legitimate influence in inclining the mind to the other...it is more probable that the legislature should have used the word (“evade”) in that interpretation which least offends our sense or justice. ... Deputy Minister/Minister of National Revenue (Customs & Excise), [1965] C.T.C. 336, 65 D.T.C. 5179 at page 5189 (Ex. ...

& W.)-per cent by weight (f) silicone—ppm (g) nickel—ppm (h) vanadium-ppm (i) aluminum—ppm or (j) conradson carbon-per cent by weight. 8. ... (e) "UTL" has for many years been in the business of buying and selling finished fuel products namely bunker fuel oil, gasoline and furnace oil at both the wholesale and retail levels; it owns oil and storage tanks in Cornwall and Morrisburg, Ontario; (f) prior to November 21, 1980, "UTL" had been selling marine fuel oil which represented only a small percentage of its business less than lot of its gross revenue; (g) "UFL"’s only business is the sale of marine fuel oil purchased as a finished product and taken delivery of in part from its supplier and contractor namely "UTL" at the Morrisburg installation or elsewhere from other suppliers; (h) the main component of marine fuel oil is Bunker C fuel (also known as #6 oil) or #6 oil diluted with furnace oil (also known as #2 oil), (i) UTL purchases on its own account as inventory and stores separately #6 and #2 oil; (j) UFL has no #6 and #2 oil inventory; (k) when UTL fulfills a purchase order for marine fuel oil from UFL, #6 and #2 oil flow from their respective storage tanks into eventually a single pipe which loading rack leads to a loading rack; UTL remains at all times in complete control of these operations; (l) when UFL purchases marine fuel oil from a non-arm length suppliers (other than UTL), #2 oil is first loaded to the delivery truck and then #6 oil is added on top which service during delivery is provided free of charge; (m) during transportation by the trucks to their final destination, #6 and #2 continue to be shaken together without consequence to the purchased product namely marine fuel oil; (n) when UFL buys marine fuel oil from arm’s lengths suppliers, it pays a flat one price charge per litre of oil; there is no broken of the price into the suppliers individual cost components; the flat one price charge is standard practice in the industry; (o) when UTL sells oil to its customers (except its subsidiary UFL) it charges a flat one price charge per litre of oil; (p) now and then when UTL stores oil for its customers it charges a flat one price charge per litre of oil (namely for the oil, storage, machinery, labour, administration, etc.); the charges relating to insurance heating and financing the oil purchase are invoiced separately; (q) UTL’s only client who receives an itemized invoice which shows a breakdown of all charges is UFL; (r) UTL sends monthly invoices to UFL showing the following charges: (1) price for #6 and #2 oil (2) storage charges at $0.0022 per litre (3) transportation (when required) at 0.009 cents a litre (4) administration, accounting office at $10 per truck load (5) rental of mixing and pumping equipment, dispatching, supervision at loading & unloading, 48 hours per ship at $8 per hour plus 25 per cent employee benefits; (s) in computing its manufacturing and processing deduction, UFL proceeds to reallocate the charge described in subparagraph (r)(4) namely: Administration, accounting office at $10 per truck load in the following manner: $3.50 is considered to be administration accounting office; $6.50 is considered to be for rental of machinery and equipment; (t) in computing its manufacturing and processing deduction, UFL proceeds to reallocate the charge described in subparagraph (r)(5) namely: Rental of mixing & pumping equipment, dispatching, supervision at loading unloading; 48 hours per ship at $8 per hour plus 25 per cent employees benefits as only labour costs; (u) consequently for purposes of computing its manufacturing and processing deduction, UFL included the following items in the various elements comprising the basic formula: Cost of Capital-is comprised of storage charges (i.e., the rental of storage tanks) at $0.0022 per litre, and rental of the blending and pumping equipment at the rate of $6.50 per load. ...

:—The appellant appeals from the assessments for its 1981, 1982,1983 and 1984 taxation years, whereby the Minister of National Revenue (the “ Minister”): (a) reclassified property acquisitions claimed by the appellant as being assets of the category of Class 29 of Schedule II of the Income Tax Act Regulations (the “ Regulations”), used directly or indirectly by the appellant principally in the manufacture or processing of goods for sale or lease into assets of the category of Class 8 of Schedule Il of the Regulations; (b) limited inventory allowances claimed by the appellant under paragraph 20(1)(gg) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... (B) the least of the amounts determined under paragraphs 125(1)(a) to (d) in respect of the corporation for the year, (C) two times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable under this Part by the corporation, and (D) the amount, if any, by which the aggregate of the corporation's Canadian investment income for the year and its foreign investment income for the year (within the meanings assigned by subsection 129(4)) exceeds the amount, if any, deductible under paragraph 111(1)(b) from the corporation’s income for the year; and 125:1(3)(a) “ Canadian manufacturing and processing profits" of a corporation for a taxation year means such portion of the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada as is determined under rules prescribed for that purpose by regulation made on the recommendation of the Minister of Finance to be applicable to the manufacturing or processing in Canada of goods for sale or lease; and (b) manufacturing or processing" does not include (x) any manufacturing or processing of goods for sale or lease, if, for any taxation year of a corporation in respect of which the expression is being applied, less than ten per cent of its gross revenue from all active businesses carried on in Canada was from (A) the selling or leasing of goods manufactured or processed in Canada by it, and (B) the manufacturing or processing in Canada of goods for sale or lease, other than goods for sale or lease by it. ...