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The relevant amounts are as follows: Net amount not remitted January to May $22,100.43 Amount not remitted for June $11,151.77 Amount not remitted for July $ 5,833.11 Total not remitted $39,085.31 Assuming that the bank was in effective control of Metropolitan after June 10, 1982, I would hold the appellant responsible for all amounts not remitted prior to June 1 plus one-third of the amounts not remitted for the month of June. ...

According to Cromwell, Bosovich ”... lined up another contract with another mill to take the remaining amount of trees from that land". ...

Well, I met with him and he suggested that it, that this was possible and — His Honour: Q. ...

In this instance the subdivision involved ”... removing /2 of the subject property from the building to facilitate the sale of the building at a reasonable market value. ...

Smelting & Refining Company Limited, [1954] S.C.R. 58, [1954] C.T.C. 28; 54 D.T.C. 1011; 5. ...

I can’t say how I arrived at $10,000 — it is just an amount which I considered to be a nominal reasonable value at the time. ...

There was no legal obligation upon Sparkle to make these payments in that they were the obligation of its sole shareholder — Riddell. ...

Total income for the 1980 taxation year $144,011.00 Less: QPP contributions $ 212.00 Unemployment insurance premiums 204.00 RRSP 4,500.00 RHOSP 1,000.00 Financial costs $24,474.00 IAA 27,338.00* Other deductions 51,812.00 51,812.00 57,728.00 Net income 86,283.00 Personal exemptions 3,880.00 Charitable donations 150.00 Interest deduction 1,000.00 Capital loss carried back from 1981 43,511.00 48,541.00 Taxable income $37,742.00 *Point at issue Having regard to the deduction in respect of taxable dividends under s 121 of the Income Tax Act, the appellant stated moreover in the said amended return that he had no tax payable for the 1980 taxation year. ...

Mr Justice Mahoney of the Federal Court — Trial Division held that the defendant was resident in Canada throughout 1972. ...

In deciding this issue the Court considered other cases relied upon by the appellant, including The Queen v Ensite Limited, [1983] CTC 296; 83 DTC 5315; The Queen v Marsh & McLennan Limited, [1983] CTC 231; 83 DTC 5180, as well as the decision of the Federal Court of Appeal in Canadian Marconi Company v The Queen, [1984] CTC 319; 84 DTC 6267. ...