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Ja-Sha Trucking & Leasing Ltd., [1992] 2 C.T.C. 139, [1992] 10 C.B.R. (3d) 41, the Manitoba Court of Appeal considered whether Revenue Canada had priority over a secured creditor claiming under a debenture securing assets including accounts receivable. ... C.A.) per Guy, J.A. at page 346; and Evans Coleman & Evans Ltd. v. ...

(First, Second & Third) v. M.N.R., [1969] C.T.C. 134, 69 D.T.C. 5109, at page 155 (D.T.C. 5121) (Ex. ... Canada (Minister of Employment and Immigration), [1989] 3 F.C. 16, 61 D.L.R. (4th) 313 (C.A.); Re Preston, [1985] A.C. 835 (H.L.). 8 ®See, for example, Pioneer Laundry & Dry Cleaners Ltd. v. ...

It doesn't seem to — it’s not a drug that makes a dramatic change. ... If I’m out and I have to do a great deal of walking, I — at the Stampede and Expo I I visited, I used a wheelchair when I was there. ...

A copy of the invoice from the law firm of Berger & Winston dated July 15, 1987 is enclosed as (Exhibit B). ... Following various exchanges of letters between the appellant’s agents and those of the respondent, a letter was sent by the agents of the respondent to the appellant’s accountant informing him that the deduction of the legal fees incurred by the appellant would not be allowed for the 1987 and 1988 taxation years because insufficient information had been provided (Exhibit A-8 — Letter dated August 17, 1989, from the audit division to the Estate of Kelly Waxman, c/o Richard Venor). ...

As the expression that's been used in the Court before, in a broad sense there is a double taxation, but not — Q. ... Armstrong & Co., [1970] C.T.C. 175, 70 D.T.C. 6148 (Exch. Ct.), which distinguished Wampole. ...

Subsection 34(6) reads as follows: (6) Section 56 of the said Act is further amended by adding thereto, immediately after subsection (11) thereof, the following subsection: (12) Subject to subsections 56.1(2) and 60.1(2), for the purposes of paragraphs (1)(b), (c) and (c.1) (hereinafter in this subsection referred to as the "former paragraphs”) and 60(b), (c) and (c.1) (hereinafter in this subsection referred to as the “latter paragraphs"), “ allowance” does not include any amount that is received by a person, referred to in the former paragraphs as "the taxpayer" and in the latter paragraphs as "the recipient", unless that person has discretion as to the use of the amount. ... In Gagnon, supra, the Supreme Court of Canada thus held that the monthly payments in question made by the taxpayer were “ allowances” within the meaning of paragraph 60(b) of the Income Tax Act. ...

Accordingly, A.V.C.s are excluded from the ambit of the rules in paragraph 147.2(4)(b) and (c) concerning service before 1990 — i.e. they are not deductible thereunder. ... The 18 per cent contribution limit applies (directly or indirectly) to all types of registered retirement income vehicles (that is, R.P.P.s, deferred profit — sharing plans [D.P.S.P.s], and R.R.S.P.s). ...

S.C. 1970-71-72, c. 63) (the"Act"), as amended and sections 7302 and 7303 of the Income Tax Regulations (” Regulations”) applicable to the 1988 and 1989 taxation years. ... At the hearing, neither the appellant nor Crown Counsel raised the fact that section 110.7 had been amended applicable to the 1988 and subsequent taxation years in such fashion that the term “ prescribed area” no longer appeared therein. ...

& Fin. 85, 8 E.R. 1034 (H.L.)]. (b) William J. compared the forged signature on the cheque with the signature on Exhibit A-2 and testified that in his opinion neither was that of his father. ... The assessment of William Tatarchuk for 1986 included the following amounts in his income: The inclusion of the sum of $66,628.67 was based on the assumption that in the 1986 taxation year William Tatarchuk, deceased, deregistered RRSP funds in the amount of $66,628.67 and that he received in 1986 RRSP funds from the National Trust Company as follows: Deemed receipt on deregistration $ 66,628.67 Deemed receipt on death 45,799.91 TOTAL $112,428.58 Contract No. 10206 $12,739.34 Contract No. 10207 12,739.33 ER 10508 41,150 TOTAL $66,628.67 It is only the sum of $41,150 that is in issue in this case. ...

As a result of this, in the appellant's words, at that juncture, “ Everything had to go on hold”. ... Teaching Gross Farm Farm Income Income Expenses Farm Losses Farm Profit 1982 $43,584 $10,100 $19,735 $ 9,635 1983 43,856 12,484 24,531 12,048 1984 44,596 10,200 22,000 11,800 1985 49,676 10,531 21,498 10,966 1986 53,332 10,239 19,155 8,916 1987 53,018 11,423 17,360 5,931 1988 54,904 12,691 14,779 2,087 1989 57,363 290 Respondent's counsel stated that all losses would have been greater had the appellant claimed capital cost allowance as required by the decision in Mold- owan v. ...