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This is the section permitting the Minister, when it is reasonably considered that collection of the amount assessed in respect of a taxpayer to be jeopardized by delay in the collection thereof, by registered letter to advise the taxpayer to pay forthwith the amount assessed or any part thereof. ...

I have also considered other submissions made by Mr. Flaherty but I find them of no substance. ...

The provisions of subparagraph (i) exclude from the deductibility of expenses provided in paragraph (o) those expenses which are of a personal and living nature, except expenses which could be considered as personal and living within the ordinary meaning of these words but only to the extent that these expenses were incurred by him while away from home in the course of carrying on his work. ...

Had she been ninety or crippled, she might have been considered a dependant under the Act, but no evidence has been offered other than the mere fact of age. ...

That subsection reads: 18 (2) Notwithstanding paragraph 20(1)(c), in computing the taxpayer's income for a taxation year from a business or property, no deduction shall be made in respect of any amount paid or payable by the taxpayer in the year and after 1971 as, on account or in lieu of payment of, or in satisfaction of, (a) interest on borrowed money used to acquire land, or on an amount payable by him for land, or (b) property taxes (not including income or profits taxes or taxes computed by reference to the transfer of property) paid or payable by him in respect of land to a province or a Canadian municipality. if, having regard to all the circumstances, including the cost to the taxpayer of the land in relation to his gross revenue, if any, therefrom for that or any previous year, the land cannot reasonably be considered to have been, in that year (c) used in, or held in the course of, a business carried on in the year by the taxpayer, or (e) held primarily for the purpose of gaining or producing income of the taxpayer from the land for that year. except to the extent that the taxpayer's gross revenue, if any, from the land for that year exceeds the aggregate of all other amounts deducted in computing his income from the land for that year. ...

In Canada Safeway, (supra, at 345 (D.T.C. 1244)) the Supreme Court of Canada considered a contention that borrowed money spent by the borrower on the acquisition of the capital stock of another company had, within the meaning of a predecessor of subparagraph 20(1)(c)(i), been "used" not for the purpose of earning dividend income but, rather, to secure other benefits which flowed from control of the new subsidiary. ...

As I follow his explanation, the set of circumstances which developed on or about October 31, 1985, which instigated his filing the application, was that he decided then his pursuit of such a settlement was not going to be successful within the year he considered to be available to him. ...

The plaintiff, on the other hand, considered that the remedy provided by the legislator in the Customs Act does not prevent an action being brought in the Federal Court, and that at this stage of the proceedings it should be given an opportunity to present the facts alleged. ...

The courts have generally held that good faith is completely irrelevant and not a factor to be considered where seizure results from failure to make a proper declaration. ...

In essence the testimony of the appellant was that he had built the house on Big Chief Road, in Orillia Township, Ontario, with the intention of retiring there some day and in the meantime rented it for what was considered to be the going rental rate for the area. ...