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Later on he went on to Say at page 193: For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly and reasonably determines to be uncollectible at the end of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact be collected. ...

Whether he would have been successful in such an assertion is not a point which needs to be considered by the Court at this time. ...

Accordingly, these amounts were considered by the Minister to be deemed salaries and assessed accordingly. (5) In 1982, 1983 and 1984 the appellant received loans from or was indebted to the Corporation and was assessed on the following amounts: $8,528 in 1982, $4,515 in 1983, and $4,733 in 1984. ...

I have considered the matter in this light as well. In my opinion, the applicant has not made out a prima facie case that the informant made a deliberate falsehood or omission or so recklessly disregarded the truth that it approached fraudulent behaviour. ...

It was in no sense a search and it could not be considered a seizure or tantamount to a seizure because there was built into section 17 a subsection providing that no penalty could be imposed for failure to comply except upon the order of a Federal Court, Superior Court or County Court judge made upon notice to the alleged offender. ...

I recognize that revenues depend on market forces and on the quality of the horses produced and that quality depends on conformation, bloodlines and other factors considered important in the market place. ...

There was no evidence of any arrangement between the appellant and Sandrin Brothers reducing the scope of the duties attached to the office of president with consequent loss of entitlement to be considered as a potential recipient of year-end management bonuses. ...

In that case the court considered the question whether a taxpayer carrying on the practice of law was entitled to deduct a fee paid for his call to the Bar. ...

Paragraph 11 of the same bulletin further states: A taxpayer who has an interest as a part owner of property is considered to own the property for the purposes of section 146.2 and paragraph 54(g) whether such ownership is legally recognized as a joint tenancy, tenancy in common, partnership or any other relationship. ...

Issue At issue in the present motion is whether the notice of appeal could be considered as being filed within the prescribed period of time. ...