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In his testimony the applicant’s accountant, Mr Lavoie, clearly stated that a notice of objection had never been considered and that he had not advised the applicant to do this because there was no documentary evidence that the said expenses had been incurred. ...

He then considered alternative forms of residential redevelopment, one of them being a small apartment building. ...

The substance of this letter should be an integral part of my judgment: Dear Vasco, My Board have very carefully considered the future of our Canadian interests and have decided to carry out the policy stated in last year’s accounts, of not maintaining any company whose profits do not seem likely to exceed £100,000. ...

Consequently, the money that the appellants received in the 1971, 1972 and 1973 taxation years was considered as benefits from their company within the meaning of subsection 8(1) of the old Act and subsection 15(1) of the new Act. ...

The position here is, I think, entirely analogous to that considered by the Exchequer Court in Gordon Kenneth Daley v MNR, 1 Tax ABC 364; 50 DTC 877. ...

Summary In the circumstances of this case, the amount in question should not be considered as a shareholder benefit conferred upon Emery in order that he be taxed accordingly. ...

These restrictions do not apply where it may reasonably be considered that collection of the amount would be jeopardized by delay. ...

Further there is no reason here as to why the appellant’s testimony should be considered as other than fully credible. ...

.- For the purposes of this subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where is has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a b 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 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. ...

For purposes of this decision, I note that the details provided in the Notice of Appeal and in the Reply to Notice of Appeal are to be considered an integral part thereof. ...