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In their respective income tax returns, the appellants had considered that they had made a capital gain on the disposition of that material in 1986. ...

John Tomac, the funds so held arose out of its business operations and were considered by him, at all times material, to be surplus funds fundamentally tied to the integrity, maintenance and growth of the business. ...

He did not deal expressly with the fact that the payments would terminate, but seemed to be content to hold that section 7, considered in the context of the whole agreement, had the primary purpose of providing for the maintenance of the wife. ...

(P) Act however, was considered at length by Judge Rip in Squires v. M.N.R., [1990] 2 C.T.C. 2640, 91 D.T.C. 62 commencing at page 2641 (D.T.C. 63). ...

Act however, was considered at length by Judge Rip in Squires v. M.N.R., [1990] 2 C.T.C. 2640, 91 D.T.C. 62, commencing at page 2641 (D.T.C. 63). ...

Those factors implying questionable behaviour of a party become, I suggest, more significant: conduct lengthening the duration, refusal to admit, improper, vexatious or unnecessary conduct – all these should be considered. ...

Standard of Review [7] Breaches of procedural fairness in administrative contexts have been considered subject to a “reviewing exercise … ‘best reflected in the correctness standard’ even though, strictly speaking, no standard of review is being applied”: Canadian Pacific Railway Company v Canada (Attorney General), 2018 FCA 69 at para 54. ...

Issues The issues in this appeal are fairly straightforward and involve a determination of whether the plaintiff is entitled to deduct the disallowed expenses totalling $13,497, $18,850.75 and $28,911.95 in the 1980, 1981 and 1982 taxation years respectively, under paragraph 18(1)(a) of the Act and whether the disallowed expenses were considered to be personal or living expenses and therefore not deductible under paragraph 18(1)(h) of the Act. ...

He considered that his worth in bonds in 1980 was some $250,000 while in 1985 it was about $400,000. ...

With regard to the restaurant Les Jardins du Luxembourg, whose lease was signed by the appellant, the cafeteria started operations on August 9, 1984 and the piano-bar and restaurant on October 16, 1984. 3.13 The statement of the source of funds for Café Bonaparte Enr. and the restaurant Les Jardins du Luxembourg reads as follows: SOURCE OF FUNDS Our summary analysis also considered the source of funds, which was identified as follows: operating income from Café Bonaparte Enr.” $230,153 operating income from Jardins du Luxembourg" 93,897 proceeds of loan secured by commercial pledge 65,000 bank overdraft 15,000 TOTAL: $404,650 [sic] The deposit slips we have traced indicate a total of $274,381, or a difference of $130,000. ...