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Hill did not retain their services, because he considered his tax return a fairly straightforward affair. ...

The appellant had the burden of establishing on a balance of probabilities that when the Minister considered the amount received by the appellant as a dividend pursuant to section 84.1 of the. ...

The Minister of National Revenue rejected the Notices of Objection and confirmed the assessments on September 18, 1995 as follows: Interest expenses to the extent of $8,941.00 in 1990, $10,948.00 in 1991, $9,113.00 in 1992 and $6,519.00 in 1993 claimed as deductions from income were denied as they were not considered to be outlays or expenses incurred by me for the purpose of gaining or producing income within the meaning of Paragraph 18(l)(a) of the Act but were personal or living expenses within the meaning of paragraph 18(l)(h) and subsection 248(1) of the Act. ...

Since its amendment in 1994, applicable to the 1991 and subsequent taxation years, subsection 118.4(1) has read as follows: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

Subsection 118.4(1) provides: For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

Under the circumstances, her testimony and that of her husband respecting her good state of health before the accident could properly be considered insufficient evidence for the purpose of excluding the other possible causes of the deafness. ...

The Appellant’s “RRSP deduction limit” for the 1993 taxation year within the meaning of paragraph 146(l)(g.l) of the Act was computed as follows: Unused RRSP deduction room, ‘nil’ end of 1992 18% of 1992 earned income of $ 8,968.00 $49,826.00 $ 8,968.00 Less 1992 PA amount 6,455.00 RRSP deduction limit for 1993 $2,513.00 The Appellant’s “RRSP deduction limit” for the 1994 taxation year within the meaning of paragraph 146(l)(g.l) of the Act was computed as follows: Unused RRSP deduction room, ‘nil’ end of 1993 18% of 1993 earned income of $ 9,167.00 $50,930.00 $9,167.00 Less 1993 PA amount 6,120.00 RRSP deduction limit for 1994 $ 3,047.00 Position of the Appellant The Appellant submits that for the purposes of paragraph 8302(2)(a) of the Income Tax Act Regulations, C.R.C. 1978, c. 945 the pension must be vested to be considered a “normalized pension”. ...

It seems to me that the partnership agreement, the relevant Partnership Act, other relevant facts and appropriate jurisprudence must be examined and considered in order to make an informed determination of the first question. ...

He considered Harvey his “best friend”. The appellant was of the view that “for five years [we] remitted faithfully”. ...

While they arrive at the same conclusion, Linden J.A. wrote the majority judgment (Robertson J.A.’s decision must be considered obiter dicta). ...