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By application of section 160, the respondent considered the appellant liable for the $32,005.55 payable to the respondent by her husband for taxes in respect of the 1970, 1971 and 1972 taxation years. ...

The Minister’s argument that the amount claimed is unreasonable would appear to mean that either Noranda did not fully reimburse the appellant on a realistic business basis for the automobile expenses he incurred on behalf of the company; or that the appellant owned and operated personally a more expensive (less economical) automobile than that contemplated in the mileage charge provided by Noranda, considered by that company to be sufficient for providing adequate transportation for Noranda’s purposes. ...

With respect to the first group of amounts, the appellant considered them to have been spent on capital account and that it was entitled to claim capital cost allowance with respect to those amounts pursuant to class 3 of Schedule B to the Income Tax Regulations. ...

The health insurance premiums paid by an employer are not considered by Canadian tax legislation to be an allowance or benefit taxable in the hands of the employee. ...

The sole issue is the valuation of the shares on V-Day and the evidence adduced in this appeal, on consent of both parties, was considered common to the following other appeals and decisions will be rendered separately in those cases: Marion D Lauder—Taxation Years 1974 & 1975 Manasu Holdings Ltd—Taxation Year 1974 Donald A Newson—Taxation Year 1974 Background The appellant held 50,001 shares of the capital stock of Hayes Trucks Ltd (hereinafter referred to as “Hayes”) which were disposed of at a price of $7.04 per share (totalling $352,007) in the 1974 taxation year. ...

According to her testimony, she did not even think of doing so, as she considered that what each owned belonged to them both. ...

The appellant considered that Mr Duquette was a good accountant and even offered to increase his remunerations. ...

Shared-Custody Parent [33] As set out above, w hen parents are “shared-custody parents”, they are both considered “eligible individuals”. ...

Even if not expressly stated in the reply, it would be relevant that she considered only one deduction to be permissible for the same property and that she reassessed to allow the more favourable deduction, i.e. the reasoning is related. [19] The proposed amendment to paragraph 40(c.1) is particularly benign because it only proposes to clarify the amount of the appellant’s claimed COGS deduction and refers to an assumption already in the reply. [20] The alternative issue/argument as framed in proposed new paragraphs 41.1, 44.1 and 44.2 states that the Minister’s reassessment to disallow the CCA deduction is more favourable to the appellant than disallowing the COGS deduction (and upholding the CCA) would have been. ...

Finally and again subsidiarily, even if the tax sought to be imposed can be considered to be in respect of an intangible, it is submitted that recourse can still be had to the doctrine of mobilia sequuntur personam if it is reasonable to use this doctrine in the circumstances (see, for example, Johnson, Conflict of Laws, 1962, at 532 ff). ...