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In Delage-Moore, Cardin, in his then capacity of Assistant-Chairman of the Tax Review Board, stated at page 2205 (D.T.C. 182-83): However, a reply to a notice of appeal by respondent will be accepted by the Board and considered valid if it is filed after the 60-day period, but before appellant makes his application to have his appeal entered on the list of appeals to be heard. ...

("Richcrest")) such as to be considered in the nature of trade, or a capital investment? ...

The application was considered on the basis of written submissions. Adrian Veldman ("Veldman") appealed an assessment of tax, notice of which is dated March 7, 1986, which was issued pursuant to subsections 227.1(1) and (10) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

The scope of this provision respecting the range of deductibility of interest has given rise to much litigation and has, therefore, been considered by the courts on many occasions. ...

Both considered the contract to be binding and to constitute an enforceable contract of sale. ...

Mugleston prepared a schedule by hand (Exhibit A-9) in which he projected the profits and the manner in which the purchase price would be paid based upon a profit margin which consists of 15 per cent of the entire purchase price, which he considered to be practical in his experience. ...

There may be circumstances under which a "director" or “officer” of a company should be considered as "part-time", but in my view that would not be an appropriate designation here. ...

Counsel said that the acquisition of the property in this case should not be on capital account but rather considered as inventory and on income account. ...

The only question that had to be considered was whether the amount claimed by the appellant was reasonable in the circumstances since the Income Tax Act does not require that receipts be filed in support of an expense. ...

Where the property has not been put to any use for an extended period of time after it was acquired or, if used, not for its intended use, the property may still be considered acquired "to be used" or “for use” if the taxpayer can show sound business reasons as to why it is not being used as originally intended, e.g., if it would be economically unsound to carry out the original intention because of unforeseen or changed circumstances. ...