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.)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) demand note not bona fide repayment arrangement Te defendant was found to be negligent in not advising of the risk that the signing by the individual plaintiff of a demand promissory note as security for a housing loan made to her would not be considered to represent a bona fide arrangement for repayment of the loan within a reasonable time. ...

., 78 DTC 6510, [1978] CTC 636 (FCTD)-- summary under Comparison of Provisions Summary Under Tax Topics- Statutory Interpretation- Comparison of Provisions "Words used more than once in a statute may not always have the same meaning, but they are normally considered to have the same meaning unless the context shows they are being used in a different sense. ...

The Queen, 78 DTC 6103, [1978] CTC 44 (FCTD)-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business In order for an undertaking to be considered a "business" it must be carried on with a reasonable expectation of profit. ...

The Queen, 96 DTC 1196, [1995] 1 CTC 2647 (TCC)-- summary under Paragraph 96(2.4)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.4)- Paragraph 96(2.4)(a) The taxpayer was not a limited partner of a partnership governed by Ontario law given that the partnership had not been registered under the Limited Partnerships Act (Ontario) in the relevant taxation years, and given that the taxpayer exercised such a degree of control in the operations that he could not be considered a limited partner even if the partnership had been so registered. ...

The Queen, 88 DTC 6352 (FCA)-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no reserve if s. 9 inclusion S 20(1)(m) only provides a reserve in respect of amounts which would be considered to be unearned in the absence of s. 12(1)(a). ...

The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business The taxpayer was not considered to be engaged in a business of making loans by virtue of the Canadian corporation of which it was a sole shareholder declaring a dividend and a stated capital reduction to be paid by way of the issuance of demand promissory notes. ...

The Queen, 95 DTC 5247, [1995] 1 CTC 333 (FCA)-- summary under Subsection 60.1(3) Summary Under Tax Topics- Income Tax Act- Section 60.1- Subsection 60.1(3) Minutes of settlement signed in 1989 in which the taxpayer's former spouse acknowledged that the taxpayer had paid to her "as and by way of maintenance during the calendar year 1988, the sum of $18,200" did not satisfy the requirement that the agreement provide that prior payments be considered to have been paid and received pursuant to the agreement. ...

Canada, 2003 DTC 5158, 2003 FCA 78 (FCA)-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit There was a personal element in the acquisition by the taxpayer of a cottage property close to that of his parents, and the Tax Court judge had properly considered all the evidence, including the fact that interest payments on the mortgage substantially exceeded gross rental revenue, in concluding that the taxpayer did not have a reasonable expectation of profit from the operation of renting the property. ...

It was stated that in drawing the distinction, the overall evidence must be considered taking into account those of the various tests that may be applicable. ...

The Queen, 2004 DTC 2232 (TCC)-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 Bonuses paid to children of the taxpayer's controlling shareholders that clearly were unreasonable in amount in relation to the services rendered by them were not deductible notwithstanding a position of the taxpayer (that was not accepted by Lamarre Proulx T.C.J.) that the bonuses should be attributed to the parent managers pursuant to s. 56(2) and, as a result, considered reasonable in relation to the services rendered by such managers. ...