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Michael’s carried with it an appointment to the University — Dr. Marotta became a lecturer. ...

Coopers & Lybrand Limited, supra, at page 6547, as follows: In Crown Tire, Strayer was required to construe the phrase as it is used in paragraph 125.1(3)(a) of the Act. ...

.: — This is an appeal by way of trial de novo from a decision of the Tax Court of Canada, dated April 5, 1991, which allowed the defendant’s appeal from reassessments for the taxation years 1980, 1981, 1982, 1983, 1984, and 1985. ...

The plaintiff’s assessment for the taxation year 1966 will be referred back to the Minister for reassessment not inconsistent with these Reasons. 1 See: Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] CTC 99; 70 DTC 6085, and Pigott Investments v The Queen (supra). ...

(r) Both corporations changed their taxation year to December 30 in 1971 and the sales and net income reported have been the following for each corpora- Defendant Covertite (Ontario) Ltd Year ending Dec. 30/71 Sales $ 806,843 $501,957 Net income 39,368 22,615 Year ending Dec. 30/72 Sales $1,141,655 $577,096 Net income 31,176 21,479 (s) The combined taxable incomes of the Defendant and Covertite (Ontario) Ltd. were as follows for the taxation years ending on the indicated dates: Jan. 31/71 62,315.09 Dec. 30/72 $70,907.00 From the figures given in (m) and (n), it is clear that the defendant company was consistently adjusting its salaries and bonuses so that the net profit remained just below the amount at which a higher tax rate would have been payable, which showed the importance of tax considerations in the defendant’s and Mr Warner’s activities. ...

. — File No. T-2626-85 [since reported at [1986] 1 C.T.C. 110; 86 D.T.C. 6027], where it was held that certiorari was available to the applicant, and the assessment and requirement to pay were quashed. ...

Whelan, who subsequently became president of Oil & Gas, Kaiser Petroleum Ltd., could add that as the events unfolded, no material changeover in personnel took place. ...

Justice Dubé in the case of Director of Investigation & Research: the Competition Act, R.S.C. 1970, Chap. ...

I cannot accept that evidence nor can I regard, as I was invited to do, the total amount of payment as representing compensation in lieu of damages. dent, this would produce a total amount of some $243,750 (ie, $75,000 39 + 12 $243,750. ...

As I appreciate the principle with respect to a finding of sham enunciated by Mr Justice Heald speaking for the Court of Appeal in the Leon case (supra) it was that while a company may be incorporated for the purposes which it was intended to be incorporated and pursued those purposes and therefore would not be a sham within the meaning of that word as laid down by Lord Diplock in Snook v London & West Riding Investments Ltd ([1967] 1 All ER 518 at 528) nevertheless such a management company may become a sham company if the agreement or transaction with that company lacks a bona fide purpose therefor. ...