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I would further observe that the Minister's authority under subsection 225.2(1) is exercisable when "... it may reasonably be considered that collection of an amount assessed... would be jeopardized by a delay...” ...

The question of whether or not the agreements are a sham has also been raised, and the case of MNR v James A Cameron, [1972] CTC 380: 72 DTC 6325, has been cited, and at page 384 [6328] thereof, there is a comment by Lord Justice Diplock in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 518 at 528. ...

. /?., [1990] 2 C.T.C. 464, 90 D.T.C. 6617 (Fed. C.A.), Hugessen, the Federal Court of Appeal stated, An election by a taxpayer under section 85 must be made in such a way that it is possible to determine in respect of which property it is made. ...

In preparing its 1980 income tax return Global deducted, pursuant to paragraph 20(1)(p) of the Income Tax Act (Canada) (the “ Act”), a bad debt expense in the amount of $1,365,676.00 (the “Bad Debt Claim”). ...

Optional Value Optional of Inventory Value of From Previous Personal Loss Year Income Inventory Expenses Year Year Consumption Reported 1977 $3,335 $4,575 $15,622 $212 $ 7,500 1978 6,607 14,644 $4,575 567 7,470 1979 4,278 5,000 18,146 413 8,455 1980 5,499 7,000 18,938 5,000 11,439 Where farm losses are incurred by a taxpayer whose chief source of income is nether farming nor a combination of farming and some other source, he may, pursuant to section 31 of the Income Tax Act, deduct only part of the loss. ...

However, the most important letter in substantive terms was that of March 1, 1984, from Mr W G Clarke, Regional Chief, Tax Interpretations — Excise to Foster Business Services Ltd, which was acting for the applicant. ...

Counsel for the parties implicated in the information argues that their rights under section 8 of the Canadian Charter of Rights and Freedoms — Part One, the Constitution Act, 1982, as amended to June 21, 1984, which provides that: 8. ...

The management fees, claimed as deductible expenses in the notices of appeal, having been consented to by the appellants, the two principal issues remaining in these appeals are—first, whether the profit realized from the sale of property referred to as the Gutta Percha & Rubber Limited property (hereinafter called “Gutta Percha property”) in September 1963 was the result of a transaction on capital account and a non-taxable capital gain or, secondly, whether the profit arose from an adventure in the nature of trade and was therefore taxable income. ...

The defendant is entitled to costs. 1 "RSC 1952 c 148. 2 *‘The taxpayer stated, in this court, that if the argument pursuant to sub section 11(3d) failed, then the contention based on paragraph 11(1)(f) failed as well. 3 7 The former corporate name was Georgian Towers Hotel Ltd. 4 Ii: The plaintiff had purchased the hotel from Delta Properties Limited who later assigned the agreement for sale to G T Holdings Ltd. 5 The terms of payment after June 1, 1975 are not relevant. 6 "I express no opinion as to what the tax position might have been. if the courts had ultimately granted recission to Oasis, or ultimately awarded damages against the plaintiff. 7 "On the particular facts of the case. the Board member went on to say of the debt in question ‘... though the debt could be looked upon as a doubtful debt in 1964. the decision as to whether the principal shareholder wishes to consider it bad or not rested entirely with him and his business judgment. 8 1 Rev 4th ed (1968). ...

In making that computation, the appellant included, pursuant to subparagraph 89(1)(l)(ii) of the Act,* [1] a sum of $1,350,555 in respect of the disposition that it had made, on December 23, 1976, of certain shares of Richards, Melling & Co. ...