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Second, and this point is even more important, the firm agreed to establish its fees [TRANSLATION] "in the same way as if 163410 were a regular client... and as if they had to be paid... by MIDLAND ". [9] The appellant's funds were thus used by Midland to pay Heenan Blaikie's fees, as is evidenced by the document entitled [TRANSLATION] "Statement of Account" in Exhibit A-10. [10] I consider that the agreement of May 12, 1992 between Midland and the appellant, to which Heenan Blaikie was also implicitly a party by reason of its undertakings (as clearly set out in paragraph 4 of the agreement), concerns the supply of legal services and alters the initial agreement between Midland and Heenan Blaikie in this regard. [11] In my opinion paragraph 4 of this agreement of May 12, 1992 is thus an agreement for a supply of legal services under which the appellant, not Midland, is designated as the person who is liable to pay the consideration for the supply. ...

The appellant said Atlantic was purchased “... to build a portfolio of rental properties so that we could keep them for long and then some day we can sell”. ...

Gray has repaid all the loans and associated interest to me on the following basis: 1986 CAD 2’000.00 1987 CAD 15’000.00 + USD 10’000.00 1988 CAD 354’500.00 1989 CAD 157’500.00 1991 CAD 22’500.00 1992 CAD 468’750.00 6. ...

Bonner" J.T.C.C. [1]               R.S. 1985 c. I-5 ...

The Appellant cannot succeed on this primary issue subject to what is stated in the following paragraph. [14] The Appellant reviewed Exhibit A-4 in oral testimony and identified the following agents from whom part or all of the 7% amounts had been recovered and remitted to Revenue Canada: Agent Amount Remitted Richard Arneson $ 34.13 Pat Berner 1,675.54 Thomas Jordens 46.69 Joan Demyen 140.63 Alma Lessard 1,406.85 Lynn Scott 532.46 Jim Griffith 150.00 Marla Lewis 332.02 Deiter Westphal 577.71 The amounts in the above table may not have been verified by Revenue Canada but I understand that Revenue Canada acknowledges that a portion of the $12,767.62 total has been remitted. ...

Kathryn Barnard, Revisor [1]               A.G. of Canada v. Kaur, 167 N.R. 98. ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] This appeal concerns the credit for a severe and prolonged physical impairment provided for in section 118.3 of the Income Tax Act (“the Act ”). [2] The impairment is caused by cystic fibrosis, which both of the appellant’s children have. ...

In so reassessing the Appellant, the Minister relied on, inter alia, the facts admitted above and the following assumptions: (a) the Appellant began operating the Activity in March, 1990; (b) the Appellant does not plan any material changes to the Activity in the near future; (c) the Appellant has no previous training or experience in the Activity; (d) at all material times the Appellant was employed on a full time basis as a teacher; (e) before starting the Activity, the Appellant prepared no business plan to determine if it would be profitable; (f) there are no major start up costs associated with this Activity; (g) there are no lease agreements or major capital expenditures required with this Activity; (h) from 1990 to 1995 the Appellant reported the following losses from the Activity, respectively as business losses: Taxation Year Gross Income Net Loss 1990 $ 325 ($4,649) 1991 $109,166 ($8,558) 1992 $261,637 ($5,312) 1993 $168,130 ($12,205) 1994 $145,174 ($14,358) 1995 $148,337 ($16,830) (i) the gross income amounts as outlined in paragraph 8(h) above, include sales and performance bonuses and tool rebates, a portion of which are paid to others; (j) revised to account for the bonuses and rebates paid out, the profit and loss statements of the Activity, including adjusted gross profit, for 1993 and 1994 are summarized as follows: 1993 1994 Sales $142,294.23 $108,648.58 Performance bonuses 25,836.74 36,526.29 Gross Income 168,130.97 147,174.87 Less: Cost of goods sold $143,463.04 $112,015.58 Bonuses paid $9,586.29 21,670.77 GROSS PROFIT: $15,081.64 $11,488.52 Operating expenses: 27,286.69 25,847.26 Net Loss $(12,205.05) $(14,358.74) (k) the Appellant did not have a reasonable expectation of profit from the Activity during the 1993 and 1994 taxation years; (l) the expenses of the Appellant in respect of the Activity were not made nor incurred for the purpose of gaining or producing income from a business or property; and (m) the expenses claimed in relation to the Activity were personal or living expenses of the Appellant. 9. ...

Justice McKenzie's order of December 5, 1994 are deductible by him under paragraph 60(c) of the Income Tax Act which in 1993 and 1994 permitted a deduction as follows: (c) maintenance — an amount paid by the taxpayer in the year as an allowance payable on a periodic basis for the maintenance of the recipient, children of the recipient or both the recipient and the children, if (i) at the time the amount was paid and throughout the remainder of the year the taxpayer was living separate and apart from the recipient, (ii) the taxpayer is the natural parent of a child of the recipient, and (iii) the amount was received under an order made by a competent tribunal in accordance with the laws of a province. [11] He contends further that Mr. ...

I also note that the advertisement the appellant purported to have published in the local newspaper for this business only refers to "amateur, commercial and digital communications – sales, service, consulting". ...