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The Abrahams judgment was considered in this Court in the 1976 appeal of Oneil Lambert v. ...

There was no argument before me on this issue, however, and it is a point of law that would be best considered after arguments from counsel ...

The taxpayer considered the notice of assessment to be a notice of original assessment of P-Ill, and cannot be faulted for doing so. ...

The overall statutory context and language of paragraph 8(1)(g) was considered by Justice Bonner in the 1980 decision of Derrien v Minister of National Revenue, 80 D.T.C. 1751. ...

., 74 DTC 6352, the Federal Court of Appeal considered subsection 12(3) of the 1952 Act as it applied to the 1960 taxation year. 12(3)     In computing a taxpayer's income for a taxation year, no deduction shall be made in respect of an otherwise deductible outlay or expense payable by the taxpayer to a person with whom he was not dealing at arm's length if the amount thereof has not been paid before the day one year after the end of the taxation year; but, if an amount that was not deductible in computing the income of one taxation year by virtue of this subsection was subsequently paid, it may be deducted in computing the taxpayer's income for the taxation year in which it was paid. [11]     In 1959, Oryx had purchased from a non-arm's length vendor a parcel of land for $174,000 paying only $1,000 in cash with the balance payable over 10 years. ...

For the advances here to be considered income receipts, the Court must be able to find that under and by virtue of his contract of employment the Appellant was entitled to commission based income and to advances on possible future earnings from time to time repayable solely out of that source which is to say that the future income if earned was to be the source and security for repayment with no liability to repay if it proved to be inadequate. ...

I had the distinct impression that they were holding something back and were giving me the bare minimum that they considered necessary. ...

Factually, the evidence does not make it possible to determine that a portion of the expenses could be reasonably considered office expenses rather than lodging expenses. [2], [3]   Appellant’s alternate argument   [37]     The Appellant’s alternate position was that the expenses were deductible as travel expenses within the meaning of paragraph 8(1)(h) ...

Dawd, as he understood it, originally could have considered the construction of his own personal residence on the Dawd property from 1967 through 1972. ...

There are three separate issues to be considered in these appeals: 1. ...