Her Majesty the Queen v. Koffler Stores Limited, [1976] CTC 313 -- text

Pratte, J (per curiam) (judgment delivered from the Bench):—The evidence supports the finding made by the trial judge that the respondent, in executing the contracts under which the payments here in question were made, had been mainly motivated by the desire to obtain the services of Gollom and Binder. In those circumstances, we are of opinion that the trial judge did not err in ruling that the deduction of those payments was not prohibited by paragraph 12(1 )(b) of the Income Tax Act.

The appeal will be dismissed with costs.

Koffler Stores Limited v. Her Majesty the Queen, [1976] CTC 311, [1976] DTC 6194 -- text

Gibson, J (orally):—At issue is the character of the payments (namely whether on capital or on revenue account) of $100,000 paid by the appellant to Parlton Drugs Limited, $2,100 paid by the appellant for the surrender of a lease of premises, and

Sudden Valley Inc. v. The Queen, 76 DTC 6178, [1976] CTC 297 (FCTD), aff'd 76 DTC 6448, [1976] CTC 775 (FCA) -- text

Addy, J:—The plaintiff, a United States company, was taxed for the years 1969 to 1972 inclusively under Part III of the Income Tax Act, RSC 1952, c 148 (hereinafter referred to as the “former Act”) and, subsequently, under Part

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