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According to Investissement et financement immobilier — Outils d’analyse et d’évaluation by Dominique Achour, when capital gains and inflation are no longer factors to be considered, the focus must be on the cash flow mathematics in order to determine the wise choice for the taxpayer; 8. ...

Whether a teacher receives one-twelfth of his annual salary at the end of each month of the year, one-tenth at the end of each of 10 months of the year, or, as in Alberta, one-twelfth at the end of each of nine months and three-twelfths at the end of a 10 th month, if his contract of service continues throughout the year, there has been no "lay-off" or "separation form... employment" giving rise to an "... interruption... in... earnings" and he is receiving his "usual remuneration"; and I do not, therefore, conceive of the circumstances in which s. 158, or some similar provision, is necessary to avoid payment of unemployment benefits to teachers who are not out of work in the ordinary acceptation of that expression. [20] Petts is cited with approval in the Supreme Court of Canada decision in Dick et al. v. ...

., docket 2000-2476-EI Date: 20001101 Dockets: 2000-2476-EI; 2000-2477-EI BETWEEN: ANDRÉ JAILLET, JACQUES JAILLET, Appellants, and THE MINISTER OF NATIONAL REVENUE, Respondent, Reasons for Judgment Somers, D.J.T.C.C. [1] These appeals were heard on common evidence at Moncton, New Brunswick, on October 4, 2000. [2] The appellants have instituted appeals from the decisions by the Minister of National Revenue (the "Minister") according to which the employment held with J & S Lumber Co. ...

The first question which I must answer, therefore, is whether the Minister has satisfied the onus of showing, under subparagraph 152(4) (a) (i) of the Income Tax Act, that the Appellants have "... made any misrepresentation that is attributable to neglect, carelessness or wilful default... in supplying any information", which in this case specifically means in filing the returns that they have filed. [6] The evidence before me with respect to that is principally the evidence of the two Appellants, which, insofar as the returns for the statute-barred years are concerned, is, as I have said, that they withdrew substantial amounts of cash, probably averaging $400 per week throughout the year, occasionally more, occasionally less. ...

They were supplied by the firm Morel & Frères. Act- analysis [29] In making her assessments, the respondent relied on ss. 3, 5(1) and 163(2) of the Act. [30]There are limits to the well-settled rule that the taxpayer has the burden of proof. [31] In the instant case the respondent had all the cheques available, both those establishing the moonlighting and those showing the reimbursements of expenses. ...

  [1] [1968] 2 Ex. C.R. 347, [1968] C.T.C. 233, 68 D.T.C. 5164. [2] [1968] 2 Ex. ...

Solicitors for the appellants: Howard, Cate, Ogilvy, Bishop, Cope, Porteous & Hansard, Montreal. ...

The taxpayer had been served three notices of reassessment in one year and the issue before the Tax Review Board was whether the reassessments were ” unfair and unreasonable” treatment by the Minister. ...

For an amount to be included in the income of a recipient as a payment of alimony or other allowance under paragraph 56(1)(b), the following conditions must be fulfilled: (1) The payments must be made either (a) pursuant to a decree, order or judgment of a competent tribunal, or (b) pursuant to a written agreement. (2) The payments must be made " as alimony or other allowance... for the maintenance of the recipient, the children of the marriage, or both”. (3) The amounts must be payable on a periodic basis. (4) At the time the payment is received and throughout the remainder of the year the recipient must be living apart from the spouse or former spouse required to make the payments, and must be separated from the spouse or former spouse as a result of a divorce, a judicial separation or a written separation agreement. ...

The term ” reasonable expectation” is not analogous to "expectation under ideal conditions”. ...