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In the 1974 statement there were three reported sources as follows, but the second one, as previously stated, was indicated to be “(without Prejudice)”: Fees earned $ 39551. ...

At 567 & 6376 respectively, Mr Justice Jackett then President of the Exchequer Court of Canada stated: With great doubt as to the correctness of my conclusion, I am of opinion that section 139(1)(e) does not operate to make a non-resident person subject to Canadian income tax in respect of a profit from an adventure that otherwise does not amount to, and is not part of, a “business”. ...

He adds that “construing the words ‘at any time’ literally and out of context means the Crown could commence proceedings today to collect tax due on a transaction back in 1915 — clearly an unreasonable result.” ...

., salary] for a taxation year from an office or employment. (6) For the purposes of paragraph 1(m), a taxpayer's “ contribution limit” for a taxation year under subparagraph 1(m)(i) or (ii) in respect of a registered pension fund or plan means such amount as is designated by the taxpayer in his return of income for the year to be his contribution limit for the year under subparagraph (1)(m)(i) or (ii), as the case may be, in respect of that fund or plan, not exceeding however the amount, if any, by which $3,500 exceeds the aggregate of amounts each of which is his contribution limit for the year under subparagraph (1)(m)(i) or (ii), as the case may be, in respect of any other such fund or plan. (8) Where an amount has been contributed by a taxpayer to or under a registered pension fund or plan... ...

Further, the documents in question were placed in the sheriff's custody by the lawyer, and not the officer, so that the sheriff did not become a " custodian" within the meaning of subsection 232(6) and as defined in subsection 232(1)(b). ...

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. ...

McFadyen, the chief assessor of the Saskatoon Income Tax Office, who was the person actually dealing with the appellant’s returns, explained that he was familiar with the returns of about 200 beer parlor operators in Saskatchewan; that 50% of these kept good records, 25 % incomplete ones and the rest practically no records; that he had arrived at the gross receipts of $32.00 per keg as a result of comparison with other returns filed in the office; that the returns from hotels that kept good records indicated that the realization from sales of draught beer amounted to $32.00 per keg or better; that he knew of cases where the return was as high as $37.00 but that he had taken $32.00 as an average. ...

The penalty assessment in each case was under subsection 163(2) and was imposed on each of them as a person who ”... knowingly... has made... a false statement... in a return. ... R., [1988] 6 W.W.R. 470 (Sask.Q.B.); Re Panarctic Oils Limited and the Queen(1982), 69 C.C.C. (2d) 393 (N.W.T.S.C.); 141 D.L.R. (3d) 138; and Matheson & McMillan v. ... & P.E.I. R. 189 (P.E.I.S.C.); 178 A.P.R. 189. 8. The fact that a corporation could not, because of its very nature, avail itself of some of the rights and freedoms confirmed or-conferred by the Charter, such as a right not to be a witness, or a right to liberty or to freedom of conscience, does not mean that other rights or freedoms which could be exercised by corporations should not be considered to have been conferred or confirmed for them. ...

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”. ...

Coopers & Lybrand Limited in its capacity as Trustee in Bankruptcy of [Indexed as: Hawboldt Hydraulics Inc. ... The taxpayer's revenues from “manufacturing and processing", using its own machinery and equipment, in the relevant taxation years are indicated below: Taxation Activities Year Chrome Repair and Re-manufacturing Application Manufacturing Parts Labour Total 1982 sub-contracted $213,751 $ 75,093 $159,556 $234,649 1983 $17,454 $121,524 $148,124 $220,058 $368,182 The revenues from repair and remanufacturing represented approximately 52 per cent and 72 per cent, respectively, of the total revenues received by the taxpayer in the 1982 and 1983 taxation years from manufacturing or processing (including "chrome applications”) for work described in categories (c) and (d). ...