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In that case as in the case at bar (at page 341 (D.T.C. 5157)): ”... the plaintiff said that he just took it for granted that they were partners but never discussed it very much". ...

Zaldin relied upon the decision of this Court in /. Stollar Construction Ltd. v. ...

Bertucci was assessed for the unremitted source deductions for the period from April to July 1985 and for August 1985 (see Exhibit I-5 — notice of assessment No. 537691), while Mr. ...

., [1969] C.T.C. 581; 69 D.T.C. 5385, Kerr, J. of the Exchequer Court of Canada stated at 594 (D.T.C. 5392-93): Coming now to consideration of the question of the character of the transaction or arrangements by which the payments in question were made, it is well settled that in considering whether a particular transaction brings a party within the terms of the Income Tax Act its substance rather than its form is to be regarded, and also that the intention with which a transaction is entered into is an important matter under the Act and the whole sum of the relevant circumstances must be taken into account. [...] ...

On November 30, 1987, Reliance entered into an agreement with the bank wherein Coopers & Lybrand were appointed as a monitor. ...

Estimated and actual expenses before interest expense and capital cost allowance for the remaining years were as follows: Year Estimated Actual Actual 1984 $4,790 $ 8,521 1985 5,276 9,339 1986 5,800 8,430 1987 6,376 6,324 1988 7,013 11,705 1989 7,714 6,846 The purchase price for the unit was $175,000 of which $126,000 was financed by way of mortgages. ...

Jeske of Jeske & Company Accounting Inc. Pennefather apparently was in charge of the office end of the business. ...

The farm was the "property" which ",.. was, immediately before the death of... ...

Subsection 152(8) is quite clear and precise, ”... subject to being varied or vacated on an objection or appeal to this Part...” ...

"within the meaning of subsection 82(1) of the Income Tax Act ("Act") and consequently were required to be included in the computation of income. and (b) amounts equal to the dividends received ”... were payable in the year to a beneficiary... ...