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I have considered what the appellant has said and have reviewed the documents provided. ...

On January 17, 1988 he returned to his regular-employment and was no longer considered by Sun Life to be totally disabled under the terms of the policy. ...

On further review, Revenue Canada officials considered that it would be unfair to disallow all the expenses and arbitrarily allowed approximately half of the amounts claimed. ...

The lump sum allowance received in 1990 was considered by Revenue Canada to be a taxable benefit from employment and to be included in the computation of the appellant's income in the 1990 taxation year. ...

All things considered, I was not persuaded by the appellant Jacques Kingsbury that he did not receive cash amounts from his former employer in the years in issue in addition to the "Christmas" bonuses. ...

Submissions The appellant submits that there should have been no interest charged for the period September 22, 1990 to April 1, 1992 because during that time the respondent was in fact a debtor to the appellant if the final determination of the refundable dividend is considered. ...

As such, I have considered and concluded that the assessment by the Minister was in accordance with the provisions of the Income Tax Act. ...

Subsection 127(8) reads (8) Where, in a particular taxation year of a taxpayer who is a member of a partnership, an amount would, if the partnership were a person and its fiscal period were its taxation year, be determined in respect of the partnership, for its taxation year ending in that particular taxation year, under paragraph (a), (b) or (e.1) of the definition "investment tax credit" in subsection (9), if (a) paragraph (a) of that definition were read without reference to subparagraph (iii) thereof, and (b) in the case of a taxpayer who is a specified member of the partnership in the taxation year of the partnership, (i) paragraph (a) of that definition were read without reference to subparagraph (ii) thereof, and (ii) paragraph (e.1) of that definition were read without reference to the words "or that reduced the amount of an expenditure made by the taxpayer under paragraph (11.1)(c)”, the portion of that amount that may reasonably be considered to be the taxpayer's share thereof shall be added in computing the investment tax credit of the taxpayer at the end of that particular taxation year. ...

The following criteria should be considered: And using Chief Justice Dickson's headings, the first is the profit and loss experience in past years. ...

It may however be helpful to forestall regular adverse awards of costs if I indicate factors which should be considered determining the balance of convenience. ...