Search - connection

The evidence is that at all the material times, and indeed for some years prior to 1967, the only occupation of the appellant Cox was in connection with the two companies, namely, Cox and Company Limited and Prairie. ...

The case most relied on by the appellant in this connection was the decision of the House of Lords in Gold Coast Selection Trust Limited v. ...

Why then should the outlays in connexion with the present transactions, compendiously described as “refunding operations’’, not also fall within the same category? ...

I GIVE DEVISE AND BEQUEATH the remainder of my property and estate of every nature and kind and wheresoever situate to my Trustees upon the following trusts, namely: (1) To pay my just debts, funeral and testamentary expenses and all succession duties, estate and inheritance taxes that may be payable in connection with any gift or benefit given by me to any persons either in my lifetime or by survivorship or by this my Will or any codicil thereto, it being my intention that all such debts, expenses, duties and taxes shall be paid out of my general estate so that all benefits and dispositions given or made by me in my lifetime or by my Will shall be free and clear therefrom. (2) As soon as possible after my death to pay the following legacies: Here follow legacies to the deceased’s mother, sister and six godchildren, totalling $55,500. (3) (a) To pay to my daughter, Mary Daintry Cole, the sum of Three Hundred Thousand Dollars ($300,000.) or, at her option, to transfer to her stocks and securities of equivalent value for the whole or part of said sum. (4) To pay and transfer all the rest and residue of my estate to F. ...

One might, for example, say the same of two sets of workings ten miles apart with no physical connection between them but conducted by the same management and staff. ...

He ran a body shop in connection with the automobile dealership and he dealt in timber berths. ...

It seems hard to disagree with this reasoning, especially so in connection with people, such as appellant’s president, so acutely awake to the thoroughness of labour practices in the highly unionized region of Metropolitan Toronto. ...

In my view, the McDonald case (supra) is an answer to the plaintiff's submissions in this connection. ...

Notwithstanding the Parties' shareholdings in the company, any profit derived by the Company from the sale of the building to be erected shall be distributed as follows:— Peter Vida Inc, Peter Vida and/or their nominees-- 66 2/3%; Berend and/or his nominees-- 33 1/3%; Any profit derived from the operation and exploitation of the said building shall be distributed in the same ratio, but after deducting therefrom the amount representing interest on the Parties' respective investment into and to the loans to the Company and the reimbursement to each Party of the amount paid by him in connection with the insurance on the life of the other referred to in paragraph 15 herein; 8 Mr Vida's explanation as to why he was to receive a share of the net profits and a share of the profits from sale of the building in excess of his shareholder's equity in the company (662/3% compared to 50%) was that since he would be operating the block and looking after the construction thereof and since the Berend brothers were fully engaged in their own lumber business and would not be actively engaged in either the construction or operation of the block, it was agreed between the partners that he should be rewarded in this manner instead of some other type of arrangement such as a salary, for example. 9 Mr Vida said that all three partners were looking for a “pension type of investment”, that he was 43 years old in 1963, that he had no other pension (excepting a $100 annuity), and the purpose of all three of the partners was to acquire the apartment block and to retain same for investment income. ...

.; (e) in return for the payment of $42,000 by Les entreprises Loma Ltée the appellant gave his personal residence as security; (f) on October 6, 1989 a cheque for $42,000 from Les entreprises Loma Ltée was deposited in the appellant's personal account, less a $1,000 cash withdrawal; (g) on the same day a cheque for $35,000 made out to Communications Daniel Morency Inc. was deposited in the company's account by the appellant; (h) the amount of $35,000 was recorded in the books of Communications Daniel Morency Inc. as an issue of capital stock to the appellant; (i) as a consequence of services rendered by Communications Daniel Morency Inc. three invoices dated August 18, October 5 and November 20, 1990 for a total of $42,000 and in Daniel Morency's own name were sent to Les entreprises Loma Ltée; (j) the appellant failed to report the sum of $42,000 as income in his tax return for 1990; (k) Communications Daniel Morency Inc. failed to report in its income tax return for 1991 the sum of $42,000 deriving from the contract between it and Les entreprises Loma Ltée, even though Communications Daniel Morency Inc. had incurred expenses in connection with this contract and claimed them as business expenses; (l) as the appellant knowingly or under circumstances amounting to gross negligence made an omission in his tax return for the 1990 taxation year by not reporting the sum of $42,000 in his income for that year, a penalty in the amount of $5,573 has been imposed pursuant to s. 163(2) of the Income Tax Act. 13 Subparagraphs 8(a) to (g), (i) and (k) of the Reply were admitted. ...