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This subsection also provides that all notices or documents mailed, served or sent to a partnership at the last known address or place of business of the partnership or any member thereof (or, in the case of a limited partnership, of any member thereof whose liability is not limited) shall be considered to have been provided to each member of the partnership. ...

The Applicant also appears to have either disregarded or failed to heed the warning in paragraph 7.2 of the Policy, which states: If prescribed forms are filed on or before the SR&ED reporting deadline (see section 6.0), but they do not contain all the prescribed information in respect of the expenditures (see section 4.1) being claimed or the prescribed information in respect of the ITC amount earned on the expenditures (see section 4.2); the claimant will not be considered to have met the filing requirements for these expenditures or ITC. ...

Whether an activity may be considered a commercial activity is a question of fact. ...

Generally, the Minister will not be considered to have met this standard of proof if a taxpayer’s conduct is consistent with two viable and reasonable hypotheses, one justifying the penalty and one not: see the Federal Court of Appeal in Panini v. ...

For the general principle that farming activities may be contracted out by the taxpayer and the latter will still be considered as engaging in a farming operation, see the decision of Cattanach J. in The Queen v. ...

At the time OLDCO was in financial trouble and owed the Appellant about $1,7 million. [22] On December 10, 1977, the Appellant increased its guarantee to the Bank to $600,000 and acknowledged that its security against NEWCO was second to the Bank's interest. [23] In 1977 and again in 1988, the Appellant waived interest owing to it by NEWCO, as NEWCO was experiencing financial difficulties. [24] In 1979, the Appellant cut off credit to NEWCO. [25] On March 27, 1980, the Board of Directors of the Appellant considered a proposal from P.M. ...

He further acknowledged therein that this system allowed the employee to have a fixed salary for a certain period, to get a better unemployment insurance benefit rate and to be able to work without being penalized, and that for the company the agreement meant that it could have manpower available at all times. [109] Michel D'Amours admitted at the hearing that he had had to pay a penalty as a result of that inquiry. [110] It is strange, if the appellant was not doing the runs, that it was still he who was signing the invoices. [111] Michel D'Amours may not have recalled the quarrel resulting in the appellant's layoff in May 1995, but the appellant acknowledged that there was indeed a quarrel. [112] If all the hours allegedly worked during the summer months had actually been worked the salary might have been reasonable, but that was not the case. [113] The above-cited text on the Civil Code reform is very interesting, but it makes it quite clear that a contract of employment is an onerous contract, which characteristic, in this case, was absent in the winter so long as there were accumulated hours. [114] The appellant's pay was clearly inflated so as to give him better unemployment insurance benefits. [115] It is true that the Civil Code of Quebec comprises a body of rules which, in all matters within the letter, spirit or object of its provisions, lays down the jus commune, expressly or by implication, and that in these matters the Code is the foundation of all other laws, although other laws may complement the Code or make exceptions to it. [116] It is also true that the Code is supplemental and s. 3(1)(a) of the Unemployment Insurance Act establishes that, to be insurable, employment must be held under a genuine contract of service. [117] Such was not the case here. [118] While it is true that the appellant lived in St-Eugène, that could not explain the arrangement discussed above. [119] Although the Unemployment Insurance Act is social legislation, its purpose is to insure real employment, which the employment here was not. [120] There may have been a synallagmatic contract of employment, but it was not insurable. [121] The appellant had the burden of proof and it was up to him to establish, if he considered it to be in his interest, the value of the car he was given by payer. [122] The appeal must therefore be dismissed and the decision appealed from affirmed. ...

I understand that he often referred to legal chicanery that he may have considered bizarre and dilatory; however, his opinion that his administration was completed after February since the only remaining assets were deposit certificates and two immovables is just as bizarre and unfounded. [36] Page 9 of the unaudited financial statements and review engagement reports dated October 7, 1991, indicates that fees of $21,935 were paid to the accountant. ...

During this period he only considered the timber which was of a butt diameter of 12 inches or more. ...

In the submission of counsel for the appellant, what should be considered is the intent of the parties- this was a sale with an intention to repurchase or a sale with a right of redemption. ...