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It is agreed that all profits earned by NETWORK will be allocated as follows: (a) Zero to $120,000 to Healy Holdings (b) $120,001 and over — 50 per cent to Healy Holdings and 50 per cent to Weber Holdings. ...

Conclusions (a) Highest & best use Because any use contemplated must be one that is reasonably feasible in an economic sense, it is imperative that appraisers focus on the market conditions as they existed at the relevant time. ...

On or about January 1, 1986, the appellant was the beneficial owner of an estate in fee simple in respect of various pieces of farmland which had been acquired before 1986 having the following legal descriptions: (i) NW 23-63-2-W5th ("Land No. 1 ") (ii) SW 23-63-2-W5th (“Land No. 2”) (iii) E 23-63-2-W5th (“Land No. 3”) (iv) NE 1-63-4-W5th ("Land No. 4") (v) NE 36-62-4-W5th ("Land No. 5") (vi) SE 6-63-3-W5th (“Land No. 6") In respect of his 1986 taxation year, the appellant had elected that his income from the farming business be computed in accordance with the cash method as defined in subsection 28(1) of the Income Tax Act, R.S.C. 1952, C. 148 (am. ...

(for Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081 (F.C.A.), the appellant used reusable bottle cases and carriers on the assembly line before and after soft drinks it manufactured were bottled. ...

The following is stated in Budget Papers of May 23, 1985, at page 56: A deduction from taxable income — $2,590 in 1985- is allowed for a disabled person, currently defined as a person who is blind at any time in the year or confined to a bed or wheelchair for a substantial period of time each day. ...

And in Banff Park Savings & Credit Union Ltd. v. Rose et al. (1982), 139 D.L.R. (3d) 764, 22 Alta. ...

It states that the appellant is indebted to Pioneer of four outstanding loans, namely: (a) $79,212 (b) $ 2,500 (c) $64,000 (This is the rights loan, Exhibit A-2) (d) the remainder of the $20,000 loan. ...

In so reassessing the appellant, the Minister made the following assumptions of fact: (a) the appellant is a Priest who, prior to 1991, was employed by the St-Jean Baptiste Parish (the "Parish") in St-Boniface, Manitoba; (b) the appellant was suspended by the Parish on September 15, 1990; (c) the appellant continued to receive his regular monthly salary in the amount of $1,392 until April 30, 1991; (d) commencing on May 1, 1991, the appellant was placed by the Parish/La Corporation Archiépiscopale C.R. de St-Boniface/La Société Ecclésiastique de St-Boniface (the "employer") on the employer's private pension and disability plan (the "plan"); (e) employees (priests) contribute five per cent of their monthly salary to the plan and parishes contribute two per cent of their Sunday collections; (f) no allocation between the pension plan and the disability plan is made with respect to employees’ contributions; (g) the plan paid the appellant 87 per cent of his regular monthly salary, namely 87 per cent of $1,392 = $1,211; (h) during the 1991 taxation year the appellant received disability (sick) benefits from May to December, i.e., 8 X $1,211 $9,688; (i) the employer charged the said disability benefits to its general ledger account #7202 "Maladie" (sickness); (j) the employer considered these disability benefits not to be taxable in the appellant's hands, and therefore made no deduction (of tax, etc.) and did not issue a T4 slip to the appellant in respect of these benefits; and (k) the appellant did not repay any portion of the said benefits received by him in the 1991 taxation year. ...

The Minister by reassessment has included in computing each of the appellants' income for the 1988 taxation year an amount as follows: Proceeds $7,630,000 Cost of Sale (6,000,000) Selling Expenses ($124,000) Gain on Sale $1,505,206 Less: Reserve (109,602) Total Gain in Year $1,395,604 [Each] Appellant's Share (25 per cent) $ 348,900 Previously Included in Income as Taxable Capital Gain 232,600 Additional Income Assessed $116,300 In 1988, a 74.5 acre parcel of land adjacent to the subject property was acquired by Araz Developments (owned by Ara Boyajian) and Sebian Developments (owned by Sayouh Boyajian), in equal shares as tenants in common and this property is still held in the same ownership. ...

By letter (the “opinion letter") dated June 14, 1989 Thorne Ernst & Whinney delivered an opinion to the BCASI on the income tax implications of the BCASI making funds available to corporations such as the appellant for SRED purposes. ...