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In that case as in the case at bar (at page 341 (D.T.C. 5157)): ”... the plaintiff said that he just took it for granted that they were partners but never discussed it very much". ...

Zaldin relied upon the decision of this Court in /. Stollar Construction Ltd. v. ...

Bertucci was assessed for the unremitted source deductions for the period from April to July 1985 and for August 1985 (see Exhibit I-5 — notice of assessment No. 537691), while Mr. ...

., [1969] C.T.C. 581; 69 D.T.C. 5385, Kerr, J. of the Exchequer Court of Canada stated at 594 (D.T.C. 5392-93): Coming now to consideration of the question of the character of the transaction or arrangements by which the payments in question were made, it is well settled that in considering whether a particular transaction brings a party within the terms of the Income Tax Act its substance rather than its form is to be regarded, and also that the intention with which a transaction is entered into is an important matter under the Act and the whole sum of the relevant circumstances must be taken into account. [...] ...

On November 30, 1987, Reliance entered into an agreement with the bank wherein Coopers & Lybrand were appointed as a monitor. ...

Estimated and actual expenses before interest expense and capital cost allowance for the remaining years were as follows: Year Estimated Actual Actual 1984 $4,790 $ 8,521 1985 5,276 9,339 1986 5,800 8,430 1987 6,376 6,324 1988 7,013 11,705 1989 7,714 6,846 The purchase price for the unit was $175,000 of which $126,000 was financed by way of mortgages. ...

. — Every person (other than a trustee in bankruptcy) who is an assignee, liquidator, receiver, receiver-manager, administrator, executor or any other like person (in this section referred to as the "responsible representative") administering, winding-up, controlling or otherwise dealing with a property, business or estate of another person, before distributing to one or more persons any property over which he has control in his capacity as the responsible representative, shall obtain a certificate from the Minister certifying that all amounts (a) for which any taxpayer is liable under this Act in respect of the taxation year in which the distribution is made, or any preceding taxation year, and (b) for the payment of which the responsible representative is or can reasonably be expected to become liable in his capacity as the responsible representative have been paid or that security for the payment thereof has been accepted by the Minister. (3) Personal liability—Where a responsible representative distributes to one or more persons property over which he has control in his capacity as the responsible representative without obtaining a certificate under subsection (2) in respect of the amounts referred to in that subsection, the responsible representative is personally liable for the payment of those amounts to the extent of the value of the property distributed and the Minister may assess the responsible representative therefor in the same manner and with the same effect as an assessment made under section 152. ...

.: — The issue in these two appeals involves the determination of entitlement to certain funds wherein Revenue Canada is the competing creditor in the first named action against the appellant, Lloyds Bank Canada ("Lloyds") and in the second action, against the appellant, Alberta Treasury Branches ("Treasury Branch”). ...

Jeske of Jeske & Company Accounting Inc. Pennefather apparently was in charge of the office end of the business. ...

The farm was the "property" which ",.. was, immediately before the death of... ...