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CRA considered that such reduction occurred, so that virtually none of Stock Dividend 2 came out of SIOH of the taxpayer respecting its shares of Newco 3 (see 6). ...

. … [W]e are of the opinion that the uncertainties in the present case are so material that the payment made when PAYG credits are purchased cannot be considered a prepayment towards the cost of any particular search. … … The supply is the viewing and downloading of documents, but it cannot be known at the time when the payment is made how many credits will actually be used and how many will remain unredeemed. ...

The difficulty in this regard was that (subject to the further difficulty that Sandini was not the trustee of the Ellison family trust) Sandini held a total of 35M shares of MIN, so that it might be considered that even after the order it had the right to decide which out of that larger pool was the block of 2.1M shares to be transferred to Ms Ellison (or, as it turned out, to Wavefront). ...

She failed to justify her interpretation of s. 3(2) (a) in light of the constraints imposed by s. 3 considered as a whole, by international treaties that inform its purpose, by the jurisprudence on the interpretation of s. 3(2) (a), and by the potential consequences of her interpretation. ...

. … Considered as a whole, the history of this investigation directly harms the integrity of the justice system and irreparably compromised the community’s sense of fair play and decency. ...