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It deducted the tax credit allowed by virtue of section 127.3 of the Act, that is to say, it calculated ”... tax payable by the corporation under Part I” for the 1984 taxation year as $5,704,134.87 being Part I tax after deducting a scientific research tax credit of $8,225,000 under section 127.3. ...

The word “ confer” means grant” or“ bestow”. In the respondent's reply to notice of appeal, in paragraphs 4(n) and (o) the following assumptions of fact are made: (n) at all material times, the appellant had appropriated the aforesaid $64,022.19 as funds or property of David Robinson Ltd; (o) a benefit or advantage has been conferred on the appellant by David Robinson Ltd. ...

The assumption “ if Part I were applicable” is difficult to apply because Part I applies on two different bases, depending on whether the taxpayer is a resident or nonresident. ...

In reply to the appellants notice of appeal, the respondent ceased to rely on subsection 14(1) of the Act, and stated the opinion that the project received by the appellant [The French text reads: “le projet tire par l'appelant' — Translator] from the “sale” of his territory was deemed to be remuneration for services rendered by the appellant in the course of his employment, in accordance with subsections 5(1) and 6(3) of the Act. [1] At the beginning of the trial counsel for the respondent explained to the Court that notwithstanding the fact that her client relied on subsection 6(3) of the Act and that the entire amount of $15,000 should be added to Mr. ...

The argument that somehow York loaned to York Boutique may be a fiction but at the same time the losses and the obligations encountered by York Boutique (the dollar basis of the alleged ” loan") were recognized as the responsibility of York—nothing could be clearer than that York eventually made good, in the name of York Boutique, for these amounts, totalling $69,000. ...

Queen & 5th, McBride July/85 $32,500 $28,200 2. 2nd Ave. Valemount Nov./85 $38,900 $32,700 3. 2nd Ave. ...

The appellant called as witnesses Isobel McNab, President of the Saskatchewan Treaty Indian Women's Council (hereinafter called the “ council”); Edith Dreaver, Executive Director of the council; Elizabeth Pratt, a secretary at the council and herself. ...

First, the introductory part of subsection 224(1.2) clearly indicates that Parliament intended to confer on the Minister of National Revenue the right to compel a person who owed money to a tax debtor or to a secured creditor to pay the money to the Receiver General of Canada, ” notwithstanding any other provision of this Act, the Bankruptcy Act, any other enactment of Canada, any enactment of a province or any law”. ...

His current financial records in relation to the horse operation with the use of the cash method and cost inclusion of new inventory in the year of purchase as expended show a clear direction towards profit: Summary of Horse Racing Activity and Horse Purchases, 1985 to 1990 Gross Revenue Total Expenses Net Loss Purchases' 1985 $26,321 $67,276 $40,955 $30,992 1986 38,458 60,735 22,277 18,340 1987 35,141 54,005 18,864 18,564 1988 27,582 32,681 5,099 — 1989 53,978 56,478 2,500 16,856 1990 66,967 69,944 2,977 12,000 NOTE: ...

On this point, I accept the evidence of Jeffrey Schrier of the accounting firm of Friedman & Friedman, whose services had been retained by the appellant in 1983. ...