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The Queen, 98 DTC 1190, Judge Rip of this Court said that for the purposes of determining whether the sum received by a taxpayer is a retiring allowance, the words "in respect of" in subsection 248(1) "direct that a broad scope of inclusion be considered as to what constitutes a sufficient connection between the loss of employment and the amounts received". [14] I find here that the Release signed by the appellant is clear enough and indicates that the $10,000.00 amount was received by the appellant in respect of the loss of her employment. ...

  [18]     Professor Fridman describes agency as a relationship that exists between two persons when one, called the agent, is considered in law to represent the other, called the principal, in such a way as to be able to affect a principal's legal position in respect of strangers to the relationship by the making of contracts or the disposition of property. [1]   [19]     An agent may act gratuitously and even in the absence of contract, because there is no consideration, the agent is still obliged to exercise care in the handling of his principal's affairs. [2] Professor Fridman cites Scrutton, L.J. in Lloyds Bank Ltd. v. ...

Lake by CCRA cannot be determinative, it is at least indicative that intervention is considered a normal and useful practice in the administration of the Act. [15] In his quality of employer, Mr. ...

The most substantial item among the disallowed expenses that gave rise to penalties is conventions and training expenses, which total $46,282 for the three years. [8] In addition to being substantial, those expenses are totally bizarre: obviously, they could not be considered legitimate in computing professional income. ...

(It also falls within subdivision d and this, I conclude, only provides for greater certainty in terms of the definition of what is income). [5] Income under section 9 is net income and expenses incurred are deductible under section 9. [18] The legal expenses incurred to enforce the pre-existing right are considered current expenses to which the prohibitions in paragraph 18(1)(a) and 18(1)(h) do not apply. ...

The evidence adduced regarding the employment itself need not be considered. [53]          There may be a number of reasons why the discussions that led to the signing of Exhibit I-2 were lengthy and difficult, but what counts as far as third parties are concerned is the notarial act, which is conclusive as to its date, and it is dated June 12, 1995. [54]          Johanne Rioux admitted that she would have liked the act in question to be retroactive to January 1, 1995, but that the appellant would not agree to it. [55]          It is true that under the civil law an agreement of wills can be equivalent to a contract, but this is true only as between the parties and not in respect of third parties such as the Minister of National Revenue. [56]          It is impossible to make uninsurable employment insurable by means of a retroactive clause. [57]          The determination under appeal must therefore be varied so that the appellant's employment is not insurable only from May 25 to June 11, 1995, and is insurable from June 12 to September 22, 1995. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Revenue Canada proposes to settle the present files as follows: Alpha Leather Canada Ltd. 1991 1992 1993 A) Expenses allowed 1) Selling salaries 8,500 10,500 7,041 2) Unrealized foreign exchange loss 122,404 B) Reduction of losses cancelled 417,448 * As discussed, the Notice of Objections for 1990 and 1994 are considered invalid. for the Chief of Appeals Montreal District Office ACCEPTANCE: The undersigned, Mr. ...

Quinton, it appears he considered that the issue of his past income taxes was behind him and that he had no need to worry. [5] The Appellant also submits that she and Mr. ...

There was no reassessment for 2008 because it was considered the year during which the appellant exceeded the $30,000 mark for gross income. ...