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At 11 % interest, an increased expense of $6,600 is very close to the loss reported in each of the three years. ...

Appeals allowed. 1 At all relevant times, the Appellant was employed under contract by the province of On tario to assist in the production of various publications, etc. and appears to have worked at the offices of various Ministries. 2 A TD-1 form is generally provided to an employee by an employer to be completed for the purpose of providing the employee’s basic personal tax exemptions and other relevant infor mation to permit the employer to properly calculate the source deductions to be submitted to Revenue Canada. 3 Exhibit R-2. 4 ^he amounts referred to are those listed in the Appellant’s Exhibit A-4. 5 > Sheffield v. ...

. /?., [1998] 2 C.T.C. 2832 (T.C.C.), a decision of my colleague Bowman, at paragraph 18, in the factual background, he said:...Ms. ...

As regards the appellant's appeal, counsel for the appellant said he agreed there had been an appropriation of funds in the amount of $7,000 but argued that there was no appropriation of funds in the amount of $35,000 because the issue of capital stock to the appellant was a mistake. 19 Counsel for the appellant referred to Lord, Sasseville and Bruneau, Les principes de l'imposition au Canada, Wilson & Lafleur, 10th ed., and in particular to paragraph 4.3.1.5, pp. 81 and 82, titled [TRANSLATION] “False statement or omission made knowingly”: [TRANSLATION] Thus, in Thibault v. ...

Scott Davidson. 13 The Respondent called one witness, an evaluation expert — Mr. ...

During the first day of the resumption of the hearing of these appeals, the appellant Pierre Daneau, who was not represented by counsel, as I noted earlier, indicated that he wished to withdraw the part of his appeals dealing with the " income tax” element of each of the four assessments but that he wanted to pursue his appeals with respect to the assessment of penalties. ...

After three years Ronald Aylward and Fabian Aylward talked about making Ronald Aylward a shareholder at some time in the future to the extent of 10- 15 % and the wages paid to him would be the same as those paid to Fabian Aylward. ... The phrase used in subsection 7(1) is: (7) Subject to subsection (1.1), where a corporation has agreed to sell or issue shares of the capital stock of the corporation — There is no further definition of the term “agreed”. ...

Therefore in 1981 when the unit was used for 71 days, 25 of which were personal and 46 of which were business, the formula application was: 46 over 71 x 100 = 64.78 per cent of expenses deductible for business or $5,865.42 out of the total expenses of $9,023.73. ... & 3. (a) Gaining or producing income from a business and (b) Personal or Living Expenses In order for the appellant to be successful under heading (a) above, he must be able to satisfy the Court on a balance of probabilities that the expenses were incurred "for the purpose of gaining or producing income from a business" within the meaning of paragraph 18(l)(a). ...

Rayner & Keeler Ltd. (No. 2) 4, at p. 935, defined the requirements of issue estoppel as:... (1) that the same question has been decided; (2) that the judicial decision which is said to create the estoppel was final; and (3) that the parties to the judicial decision or their privies were the same persons as the parties to the proceedings in which the estoppel is raised or their privies... ... It will not suffice if the question arose collaterally or incidentally in the earlier proceedings or is one which must be inferred by argument from the judgment. [...] ...

.: — Dissension reigned in 1979 among the four shareholders of Les Industries S.L.M. ... According to the Minister, S.L.M. artificially or unduly created a loss of $ 1,000,000. ...