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Accordingly, the Appellant was not entitled to a deduction of motor vehicle expenses incurred in respect of his employment by ParaMed for any of the Taxation Years. [62] The fact that the CRA may have considered a greater per kilometer allowance than that provided by ParaMed reasonable does not entitle the Appellant to deduct the difference under paragraph 8(1)(h.1) when the allowance was not included in income because of subparagraph 6(1)(b)(vii.1) and there is no evidence that the allowance was not reasonable. [17] [63] According to the T2200 forms issued to the Appellant by Spectrum, the motor vehicle allowance provided to the Appellant by Spectrum was not based solely on the number of kilometers driven by the Appellant in connection with his employment by Spectrum. ...

He considered that no portion should be capitalized as he could not find that any capital asset had been created or enhanced in value by the expen- ditures. ...

I do not believe it necessary to deal with these re-assessments otherwise than to say that on the above-mentioned date the re-assessments were to be considered as having been determined according to the provisions of the statute. ...

Argument Essentially, the assertion of counsel for the appellant was that the taxpayer’s evidence, supported by that of Mr Merchino and Mr Niles, should be accepted since the gross profit percentages indicated by the Minister’s calculations of income (about 23.8% for the first period and 67.57% for the second period) were totally unrealistic when considered against the average in the industry of 4 to 5%. ...

Those obstacles being considered, a decision was made by Bomag Germany that another company should be incorporated under a different name and it should take over the business operations carried on by Com-Pakall. ...

Le juge de la Cour supérieure a donné son agrément en ces termes: After having considered the application made by the Chief, Judicial Processes Section, special Investigations Division, based on the affidavit of Guy Drolet, I hereby approve of the above authorization, which approval is also indicated on the preceding pages by my initials. ...

It is the GMS arrangement alone which must be considered. Also, while the relationship between the plaintiff and Marlowe-Yeoman may have been created by contract, it was not an agency contract. ...

In this case, however, the Minister of the day specifically referred to explanatory notes he had published in conjunction with consideration of the bill amending the Act, and it is urged these notes be considered in support of the submission of the plaintiff about the mischief sought to be remedied, and the general purpose of the amendments, following the principle set out by MacGuigan, J.A. in Lor-Wes Contracting, supra, at 84 (D.T.C. 5314): I am strengthened in this conclusion by the clear indication of the evil sought to be remedied found in the parliamentary debates, of which as public documents this Court can take judicial notice. ...

In my view, the factual situation in the Homeplan Realty case, supra, differed from that in the Lloyd's Bank case, supra, in that there was a more obvious ambiguity in the plain meaning of the section of the statute being considered in the Homeplan Realty case. ...

In particular, this implies that the enactment's object must be considered. ...