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For those situations where the T2113 designation and T2114 information return are both late, if eligible R & D expenditures were carried out to offset the Part VIII tax liability, we will: a. accept the late-filed designation; b. apply the LFP on the designation; payment will be Collections responsibility and not a determining factor in our acceptance of the designation; and c. allow the investors' S.R.T.C.s as claimed. 2. If the R & D expenditures were not attempted, not eligible, or partially eligible: a. the designation will not be accepted; b. the LFP on the designation will be refunded, if paid; and c. the investor's S.R.T.C.s will be disallowed. ...

The classical exposition as to what constitutes a sham was given by Diplock, LJ (as he then was) when he said in Snook v London & West Riding Investments, Ltd, [1967] 1 All ER 518 at page 528: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd and the defendants were a “sham”, it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ... Finsbury Securities Ltd v Bishop (Inspector of Taxes), [1965] 1 All ER 530, and FA & AB Ltd v Lupton (Inspector of Taxes), [1971] 3 At ER 948, are not helpful in resolving the problem before me. ...

I adopt the reasoning and approach of Southey, J. in Re Borden & Elliot v. ... The individual accused can all be assumed to have suffered, to this date, the “ stigmatization of the accused, loss of privacy, stress and anxiety resulting from a multitude of factors, including possible disruption of family, social life and work, legal costs, uncertainty as to the outcome and sanction” described by Lamer, J. in Mills at S.C.R. 920, C.C.C. 539, which description was adopted by Cory, J. in Askov (at S.C.R. 1211, C.C.C. 468) to which he added at S.C.R. 1219, C.C.C. 474: There could be no greater frustration imaginable for innocent persons charged with an offence than to be denied the opportunity of demonstrating their innocence for an unconscionable time as a result of unreasonable delays in their trial. ...

Under the rule, a devise of realty to A "when" he shall attain a given age (or with any similar expression —"at" or "upon" or "from and after” but not, it seems, "if" — referring to the attainment of an age) which, standing alone, would import a contingency, will not import a contingency if the property is devised to B until A attains the age. ... & Ph. 240, 41 E.R. 482 and then only when such was accomplishable within the prescribed fiscal time constraints because the winding-up of a trust is not normally regarded as an administrative act or function qua the beneficiaries. ...

.: — The Appellant (Henry Adams) is one of 12 medical doctors whose income tax appeals were heard together on common evidence. ... For the purposes of this section, the term “Construction Advance” shall mean the advance of any moneys included in the loan budget (Schedule “B”), excluding those monies budgeted for land, the $694,050 budgeted for “Leasehold Improvements” in the space to be occupied by the Dartmouth Medical Clinic, and the $150,000 “Equity Withdrawal”. 1. … The terms in the Mercantile Bank letter (Exhibit B-5) were accepted by DMH on June 26, 1984. ...

The appellant’s income statement for 1986 indicate that its income was as follows: Development and leasing fees $ 2,297,180 Management fees 1,416,537 Share of losses of joint ventures (net of depreciation of $517,595) (167,858) Income $ 3,545,859 As of 1986, the appellant had developed ten projects. ...

The horse inventory was reflected as follows (the monetary values were provided by the appellant): As at January 1990 Item Value Value 2 mares (over 4 years old) $6,000 1 stud 5,000 2 geldings (over 4 years old) 2,000 2 yearlings 1,000 5 two-year-olds 3,000 1 pony (for family) $ 500 $17,500 In 1992 4 mares (values not itemized) 1 stud 3 aged geldings 2 yearlings 2 two-year-olds 3 foals 1 mare (for family) $20,500 As noted earlier, the plan was to have five good brood mares producing profitable sales of offspring. ... Even with lower interest rates in 1984 (10 A) and in 1985 f ^), Mr. Hoeft said he was unable to borrow to begin his feeder-cattle operation again. ...

& J. at page 13): The rule is, that when execution is executed, the property is changed; and execution is said to be executed when a sale has taken place. ... Application of the Goltz Decision to this Case In this case subsection 223(2) was invoked by the Accounting & Collections Division of Revenue Canada as a method of enforcing, by seizure, the debt owed by International Electronics Corporation to the Crown for tax assessed under Part VIII of the Income Tax Act. ...

Although Jehovah's Witnesses as a group or body have no organization as that term is ordinarily used, but are controlled and have their functions and activities directed by the directors of the Watch Tower Bible & Tract Society, and although they claim not to he a religious sect, nevertheless I think the evidence shows that they are a group which, inasmuch as they appear to have a particular system of faith or belief, might be said to come within the ordinary and general conception of the term, “religious denomination”. ... As Maclean, J. stated in Re Bien and Cooke (1944), 81 C.C.C. 316; [1944] 2 D.L.R. 137: ”... various denominations use various forms of ordination and if the procedure is satisfactory to the congregation, as appears to be in this instance, that should be considered sufficient form...”. ...

The appellant does not have control over the units; they are at the retailers and this is certainly the best location for them to serve as advertising. 3.02.5 In his testimony the witness referred to a letter to the appellant by the accounting firm Caron, Bélanger, Dallaire, Gagnon & Associés on August 12, 1983, which the respondent had appended to its reply to the notice of appeal as an argument in support of its own position. ... The test he adopted at 213 was ”... to say that capital expenditure is a thing that is going to be spent once and for all, and income expenditure is a thing that is going to recur every year", although he recognized that this test was not "to be a decisive one in every case”. ...