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The following excerpt from the judgment of Cattanach, J in Admiral Investments Limited v MNR (supra) at page 319 [175, 5121] succinctly states my views in the case at bar: What must be looked at is what was done by the appellant with a view to asking the question in Lord President Clyde’s words in CIR v Livingston, 11 TC 538, at p 542: “... whether the operations involved (in the transactions of the company) are of the same kind, and carried on in the same way, as those which are characteristic of ordinary trading in the line of business in which the venture was made.” ...

The process so far as then s 39 of the Income Tax Act was concerned was completed by Cattanach J in Vineland Quarries & Crushed Stone Ltd v Minister of National Revenue, [1966] CTC 69; 66 DTC 5092: “In my view the word 'controlled' in section 39(4)(b) contemplates and includes such a relationship as, in fact, brings about a control by virtue of majority voting power, no matter how that result is effected, that is, either directly or indirectly.” ...

The evidence is clear that the plaintiff did not extricate himself from the auto repair business in either 1978 or 1983, in part, because he could not afford to do so — the money made from employment in those businesses was being used by him to help establish his farm. ...

The bulk of judicial prose generated on the subject of fiscal residence has related to the peripatetic lifestyle of the leisurely wealthy — the jet setters of yesteryear. ...

Greenbaum (1957), 55 L.G.R. 129, he quotes: Anybody can apply for it — a member of the public who has been inconvenienced, or a particular party or person who has a particular grievance of his own. ...

Whether the “ without prejudice” qualification in the letter of January 26, 1982 would vitiate the arrangement as an agreement is a question I have not addressed. ...

Such arrangements as he did make for the receipt of mail during his absence from Canada between March 1988 and December 1989 broke down — but that, surely, cannot be laid at the feet of the Minister who acted throughout in the manner required by the Act. ...

.: — The plaintiff, Mr. Del Zotto, brings two motions. One is to amend the statement of claim pursuant to Rule 420. ...

Robertson had an arrangement with a law firm in Regina, Thauberger & Company, that where a client did not have a lawyer and wished to incorporate, they would use one of the Thauberger "shelf companies" to try to keep the costs manageable. ...

The word “ allowance” was defined in Ransom v. M.N.R., [1967] C.T.C. 346, 67 D.T.C. 5235, at page 361 (D.T.C. 5244) as follows: An allowance is quite a different thing from reimbursement. ...