Case C84
Judges:FE Dubout Ch
G Thompson M
N Dempsey M
Court:
No. 3 Board of Review
F.E. Dubout (Chairman): I have in this case had the opportunity of reading the decisions of my colleagues, Mr. Thompson and Mr. Dempsey, and I am in agreement with the conclusion that they have reached. In the circumstances in which the subject payment of $50,000 was made, I am of the opinion that there was no payment to a person who is or has been an employee, or to a person who is or has been a dependant of an employee, and accordingly the requirements of sec.78(1)(c) are not satisfied.
2. My decision therefore is that the taxpayer's objection should be disallowed and the Commissioner's assessment confirmed.
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