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The Department of National Revenue conducted a payroll audit of the Appellant in 1993 with respect to the Disputed Payment (the " 1993 Audit"). 15. ... Coopers & Lybrand Limited, agent for Mercantile Bank of Canada and Receiver and Manager of Venus Electric Limited, 80 DTC 6281 at 6287. ...

The appellant is the daughter of Murray Munn (“Munn”) who is the majority and controlling shareholder of B & M Contractor Ltd. ... Now, with respect to this matter, I’d like to ask you, did you do any work for B & M Contractors in 1983? ...

.: — The Appellant has appealed the reassessment of its 1988 taxation year ending December 31, 1988. ... Hick said the possibility that some portion of the dividend might not be taxable may have been mentioned, in passing, to the Appellant’s board on June 30, 1988 but was not focused upon because, as he said “... ...

.: — These matters were heard together on common evidence by consent of the parties on February 1 and 2, 1996 at Vancouver, British Columbia. ... Coquitlam (Owned by Parents) August 1984 September 1985 930 Sherwood Avenue Coquitlam September 1985 December 3, 1985 December 19, 1986 333 Clarke Drive Vancouver August 8. 1986 December 17, 1986 December 1. 1987 1132 Powell Street June 1, 1987 March 31, 1988 Vancouver January 24, 1987 Properties Purchased by Dellis Rand and John White Property Address First Offer Closing Date of Purchase Closing Date of Sale 2456 W. 7th Avenue Vancouver September 11, 1987 January 15, 1988 became 2458 W. 7th Avenue Vancouver May I. 1989 and 2460 W. 7th Avenue Vancouver May 31, 1989 Properties Purchased by John White Closing Date of Purchase or Property Address First Offer Agmt. for Sale Closing Date of Sale 1271 Homer Street Vancouver (100% Field Ownership) March 31, 1988 May 8, 1988 May 2, 1989 1250 Hamilton Street Vancouver 20% John White and 80% Field Ownership April 1989 January 1992 (45% interest in property sold to L intall Development & Financial Corp. resulting in Field owning the other 55% and John White owning no part.) ...

.: — The appellant appeals from reassessments under the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Counsel relied on a rather confused explanation in the land transfer tax affidavit attached to the deed to the effect that the company “... has been the sole beneficial owner during the entire period the lands have been or will be registered in the name of the grantor”. ...

.: — The appellant elected to have his appeals, from the assessments of the Minister of National Revenue (the “Minister”) for his 1987 and 1989 taxation years, heard under the Informal Procedure. ... Outside of his viva voce evidence to that effect, the only other evidence in support of this position is the T5013 Supplementary Statement of Partnership Income slip, in the name of “687420 Ontario Limited & T.E. ...

(See Canada (Minister of Employment & Immigration), v. Lidder, [1992] 2 F.C. 621, 136 N.R. 254 (F.C.A.), reversing (1987), 3 Imm. ... (See GRS Tool & Die Inc. v. The Deputy Minister of Revenue for Customs and Excise (1981), 7 T.B.R. 313, 3 C.E.R. 109 (T.B.)) 2. ...

. … 4. Prior to February 9, 1988, Mrs. Avery contacted her accounting and legal advisors in order to determine how to structure the transaction whereby she would relinquish her interest in Westminster to her brother. ... Notwithstanding paragraph 13(b), if the appellant’s tax return had been filed properly according to the instructions in the planning memorandum, a designation would have been made under paragraph 55(5)(f) which would have resulted in the realization of a capital gain of $389,553 (($700,000 (proceeds)-$270,978 (deemed dividend- safe income))- $39,469 (acb) = $389,553). ...

Obviously, the time of failure must be the time when a person failed to file a return — namely April 30 in the year following the taxation year in question. ...

Davis pointed out that the 1988 statements included, under current assets, a note receivable — Malcan Packaging for $97,750 and under current liabilities the sum of $116,571.32 as advances from a director. ... Both of these returns reported nil income, that its major business activity was inactive — no assets and that Mr. ...