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She identified Exhibit R-6, a letter signed by the appellant on Cowling & Henderson letterhead, Barristers and Solicitors, but she felt that she was dealing with the appellant as a person in authority in the Company and not as its lawyer. ... Metropolitan Police Force, 45 D.L.R. (4th) 318 (S.C.C.) and Matheson & MacMillan Ltd. v. ... & P.E.I.R. 189 at page 194 (P.E.I.S.C.) as authority. On the main issue of due diligence or reasonable care under subsection 227.1(3), the Minister says that the Company should have kept a separate account as in James V. ...

The agreement with Mercer, Lauder & Company to purchase the bonds, debentures and stock of the appellant was actually entered into on May 31, 1950. ...

., at 5241. 4 S.C. 1980-81, c. 48, ss. 10(7). 5 $ Ibid., at 5241, see also Mattabi Mines Ltd. v. ...

., [1986] 1 C.T.C. 2262, 86 D.T.C. 1214, as well as Les Conventions entre actionnaires, Editions Wilson & Lafleur, Martel Ltée, 1985, under the authorship of Paul Martel. ...

Was the " expense" in question incurred by the taxpayer for the purpose of gaining or producing income from the business? ...

The passage reads as follows: [Tax convention liberally interpreted] The accepted principle appears to be that a taxing Act must be construed against either the Crown or the person sought to be charged, with perfect strictness — so far as the intention of Parliament is discoverable. ...

This argument, however, puts a very narrow interpretation on the words ”.... amount... received... in recognition of his long service" in the definition of "retiring allowance” in subsection 248(1) of the Income Tax Act. ...

The word “regularly” means "... constantly... steadily...”. [4] Consequently, I am of the opinion that such travel by Mr. ...

While statements furnished to Mr & Mrs Herman showing the record of their respective contributions to September 30, 1967, give a break-down of the actual amounts contributed, and the interest accrued to that date on these contributions, this is not up to date to the date of their retirement, and in any event there is nothing to indicate what portion of the pension payments they receive each year results from payments contributed by them, and of course interest continues to accrue on the amounts in the fund; moreover Mr Herman testified that the payments have been increased since 1972 by an escalation for cost of living. ...

In 1952, Parliament eliminated from the Income Tax Act the rule in Section 13 (Section 10 of the Income War Tax Act) whereby the deduction of losses incurred in accessory business ventures was prohibited by providing that a taxpayer’s income “ shall be deemed to be not less than his income for the year from his chief source of income’’, and in 1958 Section 27(1) (e) was amended to provide for business losses being carried back or forward against income from any business instead of income from the same business only. ...