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Decision Below [11]            In reaching his decision the Tax Court Judge considered Mr. ...

The appellant’s second submission is that under Section 39(4) (b) for the purposes of association, where corporations are controlled by the same group of persons, this group must have the right to effectively control the corporations and if it does not, then it cannot be considered as the group contemplated in the section. ...

Counsel for the respondent therefore did not deny that the documents requested were relevant to paragraph 17 of the notice of appeal, although he considered that, as worded, the burden appeared excessive, but he denied the relevance of paragraph 17 and requested that it be struck out, because if paragraph 17 were struck out, there would no longer be any obligation to produce the documents pertaining thereto. ...

After the Meeting of March 12, 1981 Albert Kieboom 9 common shares Adriana Kieboom 1 common share 8 Class "A" common shares Yost Kieboom 8 Class "A" common shares Alma Kieboom 8 Class "A" common shares Sheila Kieboom 8 Class "A" common shares Alternately, the transactions can be considered in terms of the effect which they had on the equity of the company: 1. ...

One further matter must be considered. At the close of his argument, counsel for the plaintiff asked for triple costs, or alternatively, costs on a solicitor-and- client basis if the plaintiff were successful, because “some consideration should be given to compensate the taxpayer for [bearing the burden of] this test case.” ...

In reaching its decision, the Court considered the public policy argument against allowing the deduction of fines and penalties and drew an analogy with the tax treatment of income from illegal activities:   56. . .  ...

Paragraph 4 of IT-459 provides as follows: In determining whether a particular transaction is an adventure or concern in the nature of trade the Courts have emphasized that all the circumstances of the transaction must be considered and that no single criterion can be formulated. ...

I do not know and have not considered it.   [35]          Further, if MFSI was not incorporated until November 19, and no pre-incorporation transaction doctrine is applied, MFSI as a distinct person‑like legal entity could not have earned any income before it came into being. ...

Provision of the information and production of the documents to that officer at the time of his attendance at your office will be considered as compliance with this requirement if your acknowledgment is received on or before 19th September 1960. 4. ...

Thus, in order to reflect the deference due to the decision-maker to whom the legislature has delegated discretion, a court should not necessarily assume that it may substitute its view on, for example, issues of propriety of purpose and the relevance of the factors considered: see Baker v. ...