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The following provisions of the Income Tax Act are in play: 5. (1)... a taxpayer’s income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by him in the year. 6. (3) An amount received by one person from another (a) during a period while the payee was an officer of, or in the employment of, the payer, or (b) On account or in lieu of payment of, or in satisfaction of, an obligation arising out of an agreement made by the payer with the payee immediately prior to, during or immediately after a period that the payee was an officer of, or in the employment of, the payer, shall be deemed, for the purposes of section 5, to be remuneration for the payee’s services rendered as an officer or during the period of employment, unless it is established that, irrespective of when the agreement, if any, under which the amount was received was made or the form or legal effect thereof, it cannot reasonably be regarded as having been received (c) as consideration or partial consideration for accepting the office or entering into the contract of employment, (d) as remuneration or partial remuneration for services as an officer or under the contract of employment, or (e) in Consideration or partial consideration for a covenant with reference to what the officer or employee is, or is not, to do before or after the termination of the employment. 56. (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (a) any amount received in the year as, on account of or in lieu of payment of, or in satisfaction of, (ii) a retiring allowance, (viii) a termination payment; 248. (1) In this Act “retiring allowance” means an amount received upon or after retirement from an office or employment in recognition of long service or in respect of loss of office or employment (other than a superannuation or pension benefit), whether the recipient is the officer of employee or a dependant, relation or legal representative; “termination payment” for a taxation year means an amount equal to the lesser of (a) the aggregate of all amounts each of which is an amount received in the year in respect of a termination of an office or employment, whether or not received pursuant to an order or judgment of a competent tribunal, other than (i) an amount required by any provision of this Act (other than subparagraph 56(1)(a)(viii)) to be included in computing the income of a taxpayer for a year, (b) the amount by which 50% of the aggregate of all amounts each of which is the amount that may reasonably be considered to be the employee’s salary, wages and other remuneration from an office or employment for the 12 months preceding the date that is the earlier of (i) the date on which the office or employment was terminated, and (ii) the date on which an agreement, if any, in respect of the termination was entered into exceeds the amount determined under paragraph (a) for each previous year in respect of that termination whether the recipient is the officer or employee whose office or employment was terminated or a dependant, relation or legal representative of the officer or employee; I do not accept the plaintiff’s thesis that this was, in fact, a $25,000 lump sum settlement of a right of action for dismissal without reasonable notice. ...

There was transmitted to the Court and also referred to by counsel for the applicant a document described as form TLA7 which stated in part as follows: Re: Notice of Objection Taxation Year 1986 The above Notice of Objection has been carefully considered and the Minister's decision is included in the following document: Notification of Confirmation for 1986 enclosed. ...

At paragraph 11, he states: In drawing the line between "ordinary" negligence or neglect and "gross" negligence a number of factors have to be considered. ...

[11]            The Judge made reference to and applied the test developed in CCLC Technologies as to whether the government body acted “in exactly the same way for exactly the same reasons as payments made by private business, that is, for the purpose of advancing the [business] interests of the payor” (Judge’s reasons at para. 46). [12]            The Judge further considered the line of jurisprudence that resulted in CCLC Technologies, namely Canada v. ...

In Interpretation Bulletin IT-514, the Canada Customs and Revenue Agency takes the position that a home office used by a doctor to meet five patients a day for five days each week is an example of a workspace which would be considered to be used on a regular and continuous basis for meeting patients. ...

He takes comfort in the decision In Re Gero, [1979] C.T.C. 309; 79 D.T.C. 5228 where the funds in an RRSP were attachable and were considered to be similar to demand bank deposits. ...

.), this Court determined that clothing could be considered to be “supplies” but could not be “consumed”. ...

., all of the surrounding facts of the subject case must be considered before deciding into which one of the first two of three categories a taxpayer who is engaged in farming must be placed for the purpose of determining his taxable income and assessing him for income tax. ...

It was the taxpayer’s election and there was no basis upon which the Minister, absent legislative authority, could be allowed to impose the choice on him even if the taxpayer considered it beneficial. ...

Such expenditures cannot in any way be considered as being for minor repairs or regular maintenance. ...