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In my opinion, the company’s records attached to affidavits R-12 and R-13 substantiate Mr DeHart’s letter to Mr Green (Exhibit R-7) in which there can be no doubt that the payments made to Gottlieb & Company were considered by the company to have been part of the appellants’ remuneration for services rendered to the Ottawa Club and deposited into the appellants’ personal bank account for administrative and investment purposes. ...

The only contingency, if it is properly termed a contingency in the present appeals was that the directors might, if they considered business conditions demanded, reduce or even cancel the fund so set up. ...

The gas for the Camaro was purchased at the same garage as that for the 4 X 4 (Transcript, p 47). 3.10 The appellant claimed 75% of the expenses for the 4 X 4 as professional use, 25% being considered personal use. ...

I agree with my learned friend, the only way he’s going to get within section 18(1)(a) and have it considered an outlay or expense incurred in that year, and for the purposes of gaining or producing income, is to have the Board consider this amount as remuneration, whether we call it salary or bonus, but remuneration for services paid. ...

The adjourned hearing will be rescheduled by the Board to provide the parties with an opportunity to bring forward further matters considered by them to be relevant to the appeal. 1 (*Quoted earlier in this decision under Contentions by the Appellant) ...

Income tax should not have been deducted, but it could not be considered critical to the determination of this appeal. ...

The direction reads as follows: Having regard to the facts and recommendations set forth in the attached memorandum dated February 28, 1974 and having considered the representations contained in letters submitted by the taxpayers’ representatives dated March 15 and June 6, 1973, I hereby direct under the provisions of subsection 2 of section 138A of the Income Tax Act that the following companies be deemed to be associated with each other for the 1970 and 1971 taxation years. ...

In summation, counsel referenced the four points given in Grossman (Supra) at page 2145 which deal with factors to be considered in such a case. ...

The evidence presented must be considered to decide what evidence should be rejected and what evidence should be accepted. ...

One of the most important rules to be followed in the interpretation of a particular provision of a statute was expressed as follows by Lord Herschell in Col- quhoun v Brooks (1889), 14 AC 493 at p 506: It is beyond dispute, too, that we are entitled and indeed bound when construing the terms of any provision found in a statute to consider any other parts of the Act which throw light upon the intention of the legislature and which may serve to shew that the particular provision ought not to be construed as it would be if considered alone and apart from the rest of the Act. ...