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Counsel put to me in argument the following fractions (Jim’s claimed winnings over total amounts paid out) with the corresponding percentages to demonstrate that Jim was not winning a disproportionately high share of the total winnings paid out by the machines in his hotel: 1992 $ 10,743 $270,668 4% 1993 $ 50,558 $385,775 13% 1994 $ 31,602 $406,236 7.7% 1 do not accept the above argument as put by the Appellants’ counsel because it is based on the assumption that Jim wins every time he plays a VLT. ...

., $6,550,000 — $600,000) and would be paid for by the assumption of the balance of the mortgage, $3,664,596 ($4,264,596 — $600,000). ... Burton, Lynch, Armsworthy, Ward & O’Neil, had advised the company that the Release of Mortgage from the Bank of Montreal had been received by them on Tuesday, December 24, 1985. ... Counsel for the appellants on the other hand suggested that precisely the opposite conclusion should be drawn from the use in paragraph 85(1)(b) of the words ”... of the consideration therefor (other than any shares of the capital stock of the corporation or a right to receive any such shares)...””. ...

Burns, in 1992, to include certain amounts paid by them to Choice Learning Centre for Exceptional Children Society (Choice) as tuition in respect of their son, Jody Burns, on the basis the payments constituted- in the relevant year- an allowable medical expense within subsection 118.2(2) of the Income Tax Act (the " Act ") which could be used in computing income tax payable for the particular taxation year by virtue of being eligible for a medical expense tax credit pursuant to subsection 118.2(1) of the Act. [3] Counsel for the respondent advised the Minister had accepted that the amounts paid for tuition, as claimed, by one or other of the appellants in the relevant year, had been paid and the Minister admitted Choice was an educational institution. [4] The appellant, Janet Burns testified she resides in Vancouver, British Columbia and is a Barrister and Solicitor. ... The New Collins Concise Dictionary Of The English Language: "handicap: 1. something that hampers or hinders 2. a contest, esp. a race, in which competitors are given advantages or disadvantages of weight, distance, etc. in an attempt to equalize their chances " The Shorter Oxford English Dictionary devoted 48 lines of type to define the word- as noun and in verb form- as it pertained to sporting events, mainly horseracing and was not particularly helpful. ... " Stedman's Medical Dictionary- 25th Edition (Williams & Wilkins) offers this definition: "handicap- A physical, mental, or emotional condition that interferes with an individual's normal functioning. ...

Limited (the "Company"), under the provisions of section 227.1 of the Income Tax Act (the " Act ") for the failure of the Company to remit to the Receiver General the amounts withheld in accordance with section 153 of the Act. [3] In the file number 98-3471(GST)I the appeal is from an assessment of the Minister, notice of which was numbered 20969 and dated October 15, 1998. By that assessment the Minister reassessed the Appellant for net GST of $17,569.05, interest of $1,434.14 and penalties of $1,339.78, under the provisions of subsections 323(1) and (3) of the Excise Tax Act (the " Act ") for the failure by the Company, at a time when the Appellant was a director, to remit to the Receiver General the amounts of net tax as required by subsection 228(2) of the Act, together with interest and penalties thereon. ... As Robertson, J.A. made it clear at page 266 when he said: " In my view, the positive duty to act arises where a director obtains information, or becomes aware of facts, which might lead one to conclude that there is, or could reasonably be, a potential problem with remittances. ...

TTW had been in the position that it either had to raise an additional $1.3 million to be able to spend $2 million on qualified research or purchase a valid $1 million dollar tax credit on or before October 10, 1984 — the day the rules changed. ... However, at some point, another coup was in the offing and difficulties arose in relations with Buz Sawyer who had become president of Triangle — and whom White devoutly believed was no longer a shareholder in Nuspar, having dumped his shares privately. ... The transaction between TTW and SAT, a corporation totally owned by White, on October 10, 1984 — the last day of the “quick flips” — is illustrative of the outrageous conflict of interest played out in the sorry saga of TTW's history. ...

At all material times, the voting shares of Emdulis Ltd. were held as follows: Shareholder*Class & No. of Shares Gwendolyn Duha500 common Emeric J. ... On February 8, 1984 Marr’s subscribed for 2,000 Class "C" preferred voting shares of Duha #2 for a subscription price of $2,000 ****. 19. ... In support of her client’s submission, appellant’s counsel referred to the reasons for judgment of the Exchequer Court of Canada in International Iron & Metal Co. v. ...

This figure represented the total of two amounts, namely the gain of $1 made on the sale of 3,454,714 shares to 2170 and the negative ACB of $155,600 [100- 1,955,700- 1,000,000 + 2,800,000] [4] on these shares. The total capital gains reported by members of Groupe Ledoux thus represents the sum of $535,605 [(3 x 100,001) + 80,001 + 155,601] and the auditor added this amount as actually being business income made by Mr. ... — each trust received $100,100, Mr. Ledoux $80,100 and Douxel $2,955,700. ...

From this paragraph, she quoted the following excerpt: " Les réparations au toit et au système de chauffage sont considérées comme des grosses réparations. ...

Frappier's claim is made under paragraph 8(1)(f) of the Income Tax Act, which reads: 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: (f) — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for the taxpayer's employer, and (i) under the contract of employment was required to pay the taxpayer's own expenses, (ii) was ordinarily required to carry on the duties of the employment away from the employer's place of business, (iii) was remunerated in whole or part by commissions or other similar amounts fixed by reference to the volume of the sales made or the contracts negotiated, and (iv) was not in receipt of an allowance for travel expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing the taxpayer's income, amounts expended by the taxpayer in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts referred to in subparagraph (iii) and received by the taxpayer in the year) to the extent that such amounts were not (v) outlays, losses or replacements of capital or payments on account of capital, except as described in paragraph (j), (vi) outlays or expenses that would, by virtue of paragraph 18(1)(l), not be deductible in computing the taxpayer's income for the year if the employment were a business carried on by the taxpayer, or (vii) amounts the payment of which reduced the amount that would otherwise be included in computing the taxpayer's income for the year because of paragraph 6(1)(e). 4 Although the considerations that underlie the determination that must be made here are the same whether her income is from a business (section 9) or from employment (section 8) it was agreed that the case should proceed on the basis that she was employed by a brokerage firm and that it was therefore unnecessary to consider whether her income was from a business. ...

Analysis The principle set out in paragraph 6(1)(a) of the Act is that there shall be included in computing the income of a taxpayer " “the value of board, lodging and other benefits of any kind whatever received or enjoyed by him in the year in respect of, in the course of, or by virtue of an office or employment,...”. ...