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Accordingly, I have instructions to proceed with a Petition for Divorce and Motion, if we do not have confirmation that the terms in paragraphs 1 – 10 are acceptable, within five days. ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] This is an appeal for the 1995 taxation year. [2] The issue is whether the appellant knowingly, or under circumstances amounting to gross negligence, failed in his 1995 income tax return to report a capital gain on the disposition of qualified shares of a small business corporation, in respect of which gain subsection 110.6(2.1) of the Income Tax Act ("the Act ") provides for a $375,000 exemption in computing taxable income. ...

The assessments impose upon the Appellants the outstanding liability of the various companies for source deductions made by the companies from their employees for income tax, both federal and provincial, and for contributions under the Unemployment Insurance Act (as it then was called), and the Canada Pension Plan, together with penalties and interest. [1] The assessments in question are as follows: Company Assessment date Amount for Daniel Iannuzzi Daisons January 20, 1993 $175,245.15 Corcan January 20, 1993 $575,012.97 Fotoset January 20, 1993 $302,848.10 VitaSana January 20, 1993 $ 52,302.75 for Elena Caprile Daisons January 20, 1993 $175,245.15 Corcan September 21, 1994 $657,093.51 [4] By agreement of the parties, the six appeals were heard together on common evidence. [5] There is no dispute as to the extent of the liability of the various companies at the relevant dates. ...

When determining if a taxpayer has a “ reasonable expectation of profit” one must place some emphasis on the word reasonable”. ...

The cephalometric diagnostic program being developed was in Queen's words ”... totally innovative in that there was no other such program on the market. ...

In the French language version of the statute, the corresponding word is “ principaux”. ...

.: — This is an appeal from an assessment of income tax made by the Minister of National Revenue (the “Minister”) on April 11, 1994 with respect to the appellant’s 1992 taxation year. ...

Under this agreement of purchase and sale the partnership agreed to pay the purchase price of $13,500,000 to Salloum Doak, Barristers & Solicitors, in trust, to be disbursed to the Bank of Montreal, the appellant’s creditor prior to the partnership, when clear title to the Capri assets was registered in the name of the partnership. 10. ...

.: — The Appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) for his 1988 and 1989 taxation years whereby the Minister added to his income, pursuant to subsection 15(1) of the Income Tax Act (the “Act”), the amounts of $374,000 for 1988 and $445,675 for 1989 as a shareholder’s benefit from Fobasco Limited (“Fobasco”) with respect to the use by the Appellant of a Florida condominium owned by Fobasco. ...

.: — Before commencing with the evidence counsel for the Appellant made a motion for the change of name of the Appellant from Guerette to Barnard as she had married since the filing of the Notice of Appeal. ...