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Additionally, as regards the selling price balance of $1,459,437.39, corresponding to the plaintiffs" hypothecary obligations in connection with the loans made to them for construction of the buildings in question, the evidence further disclosed that they were in fact assumed by Cytro to the plaintiffs" benefit. ... The result of doing so was to accept as the gross selling price of the units the aggregate prices agreed to by their purchasers less the cost of construction financed by way of first mortgage. [18]      In the case at bar, I consider that the circumstances justified the Minister in changing his mind, which he may generally do from one taxation year to another, and considering that no amount could have been regarded as reasonable in respect of the 1971 taxation year for purposes of a reserve within the meaning of s. 85B(1)(d) of the Act, 1 for all the following reasons: "      the balance of the selling price on the plaintiffs' property at December 31, 1971, $1,093,467.52, corresponded exactly to the balance of the plaintiffs' hypothecary debts on the same property which were expressly assumed by the subsequent purchaser Cytro; "      the selling price balances owed the plaintiffs, namely $230,000 and $200,000, when they sold their property on August 1, 1962 were paid to them in full before December 31, 1971; "      between August 1, 1962, the date their property was sold, and December 31, 1971, the end of the fiscal year in question, the plaintiffs, still holding obligations assumed to them by the purchasers Sutton and Charlton, and still bound to their own hypothecary creditors, had in fact agreed that their hypothecary obligations would be paid in full by a subsequent purchaser of their property; "      the plaintiffs in fact benefited before December 31, 1971 from the full profit from the sale, $678,272, in view of the amounts from their hypothecary loans in question, the cash payment of $330,280.81 on the day of the sale and the repayment of the balances of $230,000 and $200,000 owed to them by the purchasers of their property; "      after the sale of their property, as they never had to pay their hypothecary creditors directly, the latter"s rights having been entirely assumed and observed by a subsequent purchaser of the property in question, the plaintiffs were not required after 1971 to lay out any sum in connection with the property and its related hypothecs. [19]      For all these reasons, the appeals cannot be allowed and the action of each of the plaintiffs is dismissed. ...

In this connection, the case of The Queen v. Melford Developments Inc., [1982] C.T.C. 330; 82 D.T.C. 6281 was referred to. ... The question is not that, but whether the collateral legislative action in connection with the Income Tax Act has the effect of amending the 1956 statute. ...

He was ultimately convicted of fraud in connection with these activities, and funds seized by the police were released to charities pursuant to a restitution order. ... Zins makes the following submissions in connection with this request: 10.       ...

(6) what is the quality of the connection with Canada: is it more substantial than that which exists with any other country?   ... (f)        What is the quality of the connection with Canada: is it more substantial than that which exists with any other country?   ...

Dussault, J.T.C.C. [1] The respondent has brought in connection with the appeal by each of the appellants a motion the main purpose of which is to obtain an order granting leave to withdraw admissions that her representative made in an examination for discovery held on March 27, 1998. [2] In 1991 and 1992, the appellants signed contracts with some Quebec universities. ... The second matter is one of the points in issue in ultimately determining whether the appellants are entitled to the input tax credits claimed in connection with these contracts. [3] On March 27, 1998, Guy Du Pont, one of the appellants’ counsel, conducted an examination for discovery of Luc Guénette, an auditor with the Direction générale de la vérification et des enquêtes (audit and investigation branch) of the Quebec Department of Revenue. ...

In other words, such a challenge, in order to be properly before the Court, must be brought in connection with some form of administrative action being contested so as to trigger this Court’s jurisdiction.  ... [15]            I take this finding of the Federal Court of Appeal to mean that a litigant cannot bring a “stand-alone” constitutional challenge by way of a judicial review application absent any type of connection with some actual conduct triggering his or her right to bring a judicial review application and engaging, as a result, the Court’s jurisdiction to consider the matter.  ...

There is no necessary connection between s. 56 and s. 132, since the Minister may exact penalties under s. 56 (extrajudicially so to speak, although subject to taxpayer challenge) without summary conviction proceedings being taken under s. 132. A connection arises however between s. 56 and s. 132(3) when there has been a conviction under s. 132(1)(d) and the Minister was also disposed to assess a penalty for the same conduct as expressed in s. 56(1). ...

In connection with the sale of fifty per cent of the shares of the company a warranty was given to the purchaser that “the company has claimed on its tax returns and has reserved on its books at least the depreciation referred to in a letter…” The letter noted “full depreciation in the accounts” for fiscal years 1967 and 1968, estimated depreciation as a charge against retained earnings prior to 31 May 1966, and full depreciation at capital cost allowance rates to 31 May, 1968. ... There is no necessary connection between [Page 215] depreciation and capital cost allowance. ...

Levert pleaded guilty in connection with the instant cases to charges of conspiracy to avoid tax and enabling tax of $110,000 to be avoided by taxpayers, including the respondents, for the 1986 to 1988 taxation years. ... A probation order for two years was also made against him, prohibiting him from acting directly or indirectly as an appraiser, promoter, broker or consultant in connection with gifts of art works to non-profit organizations. [5]      For 1986 to 1989, Mr. and Mrs. ...

Given this tax debt, Revenu Québec had seized the cranes from Crane. [46]       These cranes among the seized property are the following: 2.1 Ford 9000 truck, orange NS/ W9OJVHA6973 with boom, registration L86164; 3.1 Grove crane, model 4080 NS/ R21365, registration FN98335; [47]       There are two paradoxes in connection with these cranes. [48]       First, these cranes are covered in contract D.1, which we reviewed earlier. ... However, it covers two distinct properties, namely: 6.1 Pontiac Transport vehicle, green, registration FM12051, NS/1GMDU06D2RT213152; 7.1 Jaguar vehicle, grey, without engine, registration FE96635; [51]       There is also a paradox in connection with this latter contract. ...