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The plaintiff was required, in order to carry out his duties as a plainclothes officer and receive a salary as such, to incur certain expenses regarding his clothing, and reimbursement of these expenses should not be considered as conferring a benefit under paragraph 6(1)(a) of the Act... ... Appeal dismissed. 1 Paragraph 6(1)(a) and the relevant portion of paragraph 6(1)(b) read as follows: 6. (1) There shall be included in computing the income of a taxpayer for a taxation year as income from an office or employment such of the following amounts as are applicable: (a) the value of board, lodging and other benefits of any kind whatever (except the benefit he derives from his employer's contributions to or under a regis tered pension fund or plan, group sickness or accident insurance plan, private health services plan, supplementary unemployment benefit plan, deferred profit sharing plan or group term life insurance policy) received or enjoyed by him in the year in respect of, in the course, or by virtue of an office or employment; (b) all amounts received by him in the year as an allowance for personal or living expenses or as an allowance for any other purpose, except... 2 [1983] C.T.C. 393; 83 D.T.C. 5409 3 Section 3 is now paragraph 6(1)(a)—the paragraph here being considered. ...

Daoust, the bank considered him as the true owner beginning on April 15, 1982, and all the rest was only the settlement of an existing situation. ... Daoust become and be considered the owner of the said business capital following the date on the promise to sell mentioned above, i.e. ...

The respondent's appraiser also considered a V-Day income approach to value, but the rental or income produced resulted in a lower value than the direct sales comparison approach and so was discarded. ... The third method was not even considered by either appraiser, while the second was only briefly touched on by the respondent's appraiser and discarded. ...

Vouchers in the amount of $500.70 were not accepted, because they were considered inadequate for entertainment purposes. ... Gilling, [1990] 1 C.T.C. 392; 90 D.T.C. 6274, at 398 (D.T.C. 6278), which assert that even if it is not explicitly stated in the contract that one must pay one's own expenses, this can be considered as implicit, given the terms and conditions of the job. ...

Accordingly, my client's averaging period consisting of four of the six immediately preceding years should be considered correct within the interpretation of 119(4). ... I can only conclude that the earlier reference to the year 1977 was related in some way to an effort on the part of the appellant to utilize the years he considered most advantageous to him, not unlike the instant case. ...

Only those corporations which are considered “small” enough pursuant to the formula contained in the Act are able to benefit from the deduction. ... This precise issue had been considered by the Federal Court of Appeal in the case of The Queen v. ...

That notice of confirmation reads in part: The formal objection(s) which you made to the notice(s) of Redetermination of a Loss for income tax in respect of taxation year(s) 1979 & 1980 has (Have) been carefully considered in accordance with paragraph 165(3)(a) of the Income Tax Act. The Minister of National Revenue has considered the facts and reasons set forth in your Notice(s) of Objection and hereby confirms that the Notices of Redetermination of a Loss has (have) been made in accordance with the provisions of the Income Tax Act for the following reasons: Consequent upon receipt of the notice of confirmation the plaintiff proceeded with its appeal to the Tax Court. ...

The improvements were considered to have been in average condition at the date of valuation. ... Blaauw specifically considered, as an added factor, that the subject property at the date of valuation consisted of a house and a garage and that it had been improved to permit its use as a revenueproducing rental property. ...

In support of the motion counsel for the respondent also argued that there had been no notice from the appellant that an application under Rule 7 was being considered. ... I have considered Rules 6, 7 and 8, counsel's submissions and the reasons of Taylor, T.C.J. in Cotroneo v. ...

Dealing with the matter of the transaction being at arm's length it is difficult to comprehend that when a person who is a shareholder, director and president of a company receives shares, even though he abstained from voting on the issuance to him of the shares, can be considered to be dealing at arm's length. ... Thus they could not be said to be dealing at arm's length when the true substance of the transaction was considered. ...