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Riddell to include in his income the following amounts: (a) the following interest paid by Sparkle on on the loans on behalf of Riddell; 1977: $28,990.59 1978: $27,556.68 1979: $27,373.97 1980: $39,923.97 (b) the following sums alleged by the Minister to be the principal portion of the loans paid by Sparkle on behalf of Riddell: 1977: $11,990.67 1978: $9,900.00 1979: $7,812.22 1980: $2,553.83 These amounts were considered by the Minister to be an appropriation of the property of Sparkle by Riddell, and therefore taxable in accordance with subsection 15(1) of the Income Tax Act; and (c) allowing Mr. ...

That doubt is intensified and becomes disbelief when the objective facts are considered. ...

Now, you mentioned that you considered that your properties, for example, had gone up in value I take it, and that was one of the reasons why you were liquidating? ...

This only produced 17 orders which was considered an inadequate response. ...

.), that: To determine whether a person has ceased to be resident of any particular place, the duration of his previous residence, his connections with that community and his interest in it are circumstances to be considered. ...

The criteria Dickson, J. states should be considered are: the profit and loss expenses in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

This proposition appears not to have been considered by counsel and was not canvassed in their submissions which proceeded on the basis of the issue of priority turned on whether the charge was fixed or floating. ...

Raymond, [1980] C.T.C. 520, 80 D.T.C. 6383, the Federal Court of Appeal considered an instance in which a bailiff, under writ of execution, had seized and paid money into court. ...

He maintains that they should be considered as being reimbursements for expenses, although they cannot be quantified. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...