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A difference in salary or wages based on experience, seniority, years of service, merit, productivity or overtime is not considered discriminatory if such criteria are common to all members of the personnel. ...

The Judgments must therefore be considered to have been made ex parte. ...

His primary submission appears to be "monies reallocated at the audit should have been considered a payment to the shareholder for services rendered and not a benefit under section 15. [2] He added that if the advances in question are not allowable business expenses to the corporation then he is entitled to post them to the $100,000 loan account owed to him by the corporation. [6]      The Respondent relies in part on the fact that this is not an instance where there was a bookkeeping error. ...

That the alleged partnership must be considered in the totality of the circumstances prevents the mechanical application of a checklist or a test with more precisely defined parameters. ...

  [43]     If the Minister had considered all of the facts in evidence, his decision would have been different ...

Blouse, through his agent, Ray Imbeau, suggested that the "Minister's definition of the $47,067 as income from an office or employment... be considered as dividends from 1136302 Ontario Inc. ...

After having considered the information provided at the objection stage, the Minister set this income at $17,241 for 1996, $32,197 for 1997 and $20,821 for 1998, and imposed penalties under the Income Tax Act (Act). [2]      In her Notice of Appeal, Ms. ...

Fisher, Q.C. stated at page 192:             The question of what constitutes a bad debt has been considered by the Courts on many occasions and is the subject of discussion in various books on accounting. in No. 81 v. ...

It is not advised, and indeed is even considered wrong, to make allegations such as those of counsel for the respondent. [21]     In preparing these reasons, I had some reservations about the appellant's credibility, particularly because of his testimony that, once an amount was entered in the central computer, that amount, even if entered by mistake, could not be corrected. ...

He indicated that at one point, he thought about selling this property but decided against this course of action. [15]     I turn now to the evidence relative to the financial aspects of this case, with respect more particularly the purchase of this property, its financing and improvements relating thereto, as well as the Appellant's financial circumstances. [16]     As appears from subparagraph 5(a) of the Reply to the Notice of Appeal, the subject property was purchased for $87,500.00, which the Appellant considered at the time to be an attractive price. ...