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Taking this amount into account leaves a deficit in her net worth of $73,655.87 — $22,300.00 $51,355.87. ...

He submitted that the letter "... is clearly a covenant which relates to what the employee is to do; he is to continue working for Canadian Fishing Company and on termination he will receive that amount.... ...

A schedule of gross income and expenses prepared and filed by the respondent shows: Net Profit Taxation Years Gross Income Gross Expenses (Loss) (Loss) 1978 $4,389.00 $ 7,983.29 ($3,594.29) 1979 2,494.64 2,554.96 (60.32) 1980 1,249.00 4,123.49 (2,874.49) 1981 205.00 6,011.27 (5,806.27) 1982 1,752.70 3,525.96 (1,773.26) 1983 937.60 6,638.68 (5,701.08) 1984 7,977.51 16,701.19 (8,723.68) The increase in expenses in 1984 over 1983 is accounted for mainly by an expense of $3,483.82 in respect of oil which was used as fuel for the production of maple syrup and additional capital cost allowance on what appears to be machinery and equipment purchased for the same purpose. ...

On September 6, 1978, Glenn and his wife Joanne filed the requisite registration under the Business Names Registration Act (Manitoba) declaring, inter alia, that they intended to carry on business under the firm name of Lowery's Treads & Threads (Threads) and that no other person or corporation was associated with them in this business. ...

On busy days she went to the store for longer periods — Friday, Saturday, holidays and fall fair days. ...

Until the judgment of the Federal Court — Trial Division in Mother's Pizza Parlour is reversed or qualified in some significant way by the Federal Court of Appeal or the Supreme Court of Canada, I believe that the proper course for me to adopt is to accept and apply it whenever the occasion arises. ...

Appeal allowed. 1 *The parties agreed that the average rate of exchange in 1977 and 1978 was $0.3862 for G$1 in 1977 and $0.4375 for G$1 in 1978. 2 tReference to $ is in Canadian currency. 3 *lt was not clear from the evidence whether the amount of $14,000 was in the currency of Canada or Guyana. ...

. — where the taxpayer was employed in the year in connection with the selling of property or negotiating of contracts for his employer, and (i) under the contract of employment was required to pay his own expenses, (ii) was ordinarily required to carry on the duties of his employment away from his 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 travelling expenses in respect of the taxation year that was, by virtue of subparagraph 6(1)(b)(v), not included in computing his income, amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him 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), or (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 him. ...

The appellant maintained that this paragraph was based on the Beauregard decision of the Federal Court — Trial Division, [1981] 2 F.C. 543. ...

“Indefeasibly vested” — statute providing for exemptions from estate tax with respect to net estate, not exceeding specified amounts, transferred to and “indefeasibly vested” in surviving spouse or children of decedent, used quoted phrase as meaning an absolute vesting or a vesting with no strings attached as of date of decedent's death. ...