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The appellant's main defence rests on his interpretation of subsection 231.6(1) and therefore it must be considered. ...

The appellant was, moreover, considered to be an officer of the army and received all his orders from superior officers in the army, both in the area of teaching and in other areas. 3.04 In paying the appellant in 1986, the commission scolaire deducted both federal tax ($6,273.40) and Québec provincial tax ($6,460.01). 3.05 When he left Québec, the appellant had the intention of returning to live in Québec. ...

In Delage-Moore, Cardin, in his then capacity of Assistant-Chairman of the Tax Review Board, stated at page 2205 (D.T.C. 182-83): However, a reply to a notice of appeal by respondent will be accepted by the Board and considered valid if it is filed after the 60-day period, but before appellant makes his application to have his appeal entered on the list of appeals to be heard. ...

("Richcrest")) such as to be considered in the nature of trade, or a capital investment? ...

The application was considered on the basis of written submissions. Adrian Veldman ("Veldman") appealed an assessment of tax, notice of which is dated March 7, 1986, which was issued pursuant to subsections 227.1(1) and (10) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

I here again stress that every lease had a term in it in which it was the option of the taxpayer plaintiff, Plaza Pontiac Buick, not the lessee, but at the option of the plaintiff that the vehicle would be considered sold upon the expiry of the lease term. ...

The scope of this provision respecting the range of deductibility of interest has given rise to much litigation and has, therefore, been considered by the courts on many occasions. ...

Both considered the contract to be binding and to constitute an enforceable contract of sale. ...

Mugleston prepared a schedule by hand (Exhibit A-9) in which he projected the profits and the manner in which the purchase price would be paid based upon a profit margin which consists of 15 per cent of the entire purchase price, which he considered to be practical in his experience. ...

There may be circumstances under which a "director" or “officer” of a company should be considered as "part-time", but in my view that would not be an appropriate designation here. ...