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.), Tremblay-Lamer J. set out three requirements at paragraph 23, that must be met if a delay is to be considered unreasonable: (1)   The delay in question has been longer than the nature of the process required, prima facie; (2)   The applicant and his counsel are not responsible for the delay; and (3)   The authority responsible for the delay has not provided satisfactory justification. ...

Had the defendant considered it a genuine issue, she would have raised it then or, at least, far earlier than she did.   ...

Had the defendant considered it a genuine issue, she would have raised it then or, at least, far earlier than she did.   ...

In a Notice of Confirmation by the Minister dated December 14, 1988, the Minister stated in part: The Minister of National Revenue has considered the facts and reasons set forth in your Notice(s) of Objection and hereby confirms that the assessment(s) has (have) been made in accordance with the provisions of the Income Tax Act for the following reasons: The Scientific Research and Experimental Development expenditures of $25,000,000.00 with respect to the Proteus Contract are not deductible in 1985 pursuant to subsection 18(9) of the Income Tax Act. ...

It was the amount that both Dominion Security Ames and the board of directors considered to be fair as set forth in the Information Circular. ...

(as he then was) looked behind the corporate veil to determine the main purpose of a land purchase: The fact that a company was incorporated for the sole purpose of holding a single parcel of land and did not engage in any other type of business, is a factor to be considered but is by no means conclusive as to what the object of the taxpayer was in purchasing the land. [...] ...

The King, 35 D.L.R. 404, the Exchequer Court of Canada went even further, since it considered that the Minister's decision was final if, after receiving the notice of objection, the Minister did not refer the matter to the Court; at 408 and 409 the Court said the following: Sec 178 of the Customs Act (R.S.C. 1906, c. 48) provides: If the owner or claimant of the thing seized or detained, or the person alleged to have incurred the penalty, does not, within thirty days after being notified of the Minister’s decision, give him notice in writing that such decision will not be accepted, the decision shall be final. ...

Counsel for the plaintiff argues that a liberal and purposive interpretation of section 15 requires that the word “individual” be considered as including corporations which are persons in the eyes of the law. ...

For accounting purposes, commercial production was considered to commence on October 1, 1972. ...

By analogy with the decision of the Supreme Court of Canada in The Queen v Canadian Pacific Railway Company, [1971] CTC 163; 71 DTC 5078, the Plaintiff is considered to be the manufacturer for sales tax purposes of the ties creosoted in these circumstances by Domtar. 6. ...