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This actual valuation was established on the basis of the valuation by three experts, one of whom, Mr Madison H Haythe, vice-president of the well-known investment firm of Morgan Stanley & Co, testified in Court. ...

I see no reason for so limiting the scope of the words in section 24, particularly the words authorizing the Minister at any time to “... assess, re-assess, or make additional assessments upon any persons... for duties, interest and penalties”. ...

The owners insisted on selling the whole of their properties, or none at all. 11 In order of date, the deeds of purchase, and the agreed sale prices, were as follows: Mary St Louis-- April 5, 1965-- $165,750 LaPorte-- May 20, 1965-- $ 35,000 James St Louis-- June 1, 1965-- $150,000 12 The transactions were ultimately paid in cash, except in respect of the James St Louis farm. ...

It is, as applied to this case, “... his income for the year from all duties performed by him in Canada...”. 14 As has been said over and over again, the statute does not define “income”. ...

DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT   ...

The plaintiff also alleges that by reason of further sales and deliveries of such equipment and supplies in the period from August 1, 1966 to the end of 1967 the company became further liable for sales tax at 12%, making a tax liability of $715.55, which the company neglected, failed or refused to pay (paragraph 5 of the Information); and that by reason of non-payment of that liability the company became liable to penalties that amounted to $159.79 to April 30, 1970 (paragraph 6), In the Information the plaintiff alleges that the amounts remaining unpaid and owing to Her Majesty by the defendant were: Penalties to August 12, 1968, $ 602.10 Tax unpaid 715,55 Penalties on said tax to April 30, 1970 159.79 Total $1,477,44 and the plaintiff claims: (a) payment of that sum of $1,477. 44: (b) payment of additional penalties and interest accruing under the Act, until judgment; (c) costs. ...

He adds that “construing the words ‘at any time’ literally and out of context means the Crown could commence proceedings today to collect tax due on a transaction back in 1915 — clearly an unreasonable result.” ...

., salary] for a taxation year from an office or employment. (6) For the purposes of paragraph 1(m), a taxpayer's “ contribution limit” for a taxation year under subparagraph 1(m)(i) or (ii) in respect of a registered pension fund or plan means such amount as is designated by the taxpayer in his return of income for the year to be his contribution limit for the year under subparagraph (1)(m)(i) or (ii), as the case may be, in respect of that fund or plan, not exceeding however the amount, if any, by which $3,500 exceeds the aggregate of amounts each of which is his contribution limit for the year under subparagraph (1)(m)(i) or (ii), as the case may be, in respect of any other such fund or plan. (8) Where an amount has been contributed by a taxpayer to or under a registered pension fund or plan... ...

Coopers & Lybrand Limited in its capacity as Trustee in Bankruptcy of [Indexed as: Hawboldt Hydraulics Inc. ... The taxpayer's revenues from “manufacturing and processing", using its own machinery and equipment, in the relevant taxation years are indicated below: Taxation Activities Year Chrome Repair and Re-manufacturing Application Manufacturing Parts Labour Total 1982 sub-contracted $213,751 $ 75,093 $159,556 $234,649 1983 $17,454 $121,524 $148,124 $220,058 $368,182 The revenues from repair and remanufacturing represented approximately 52 per cent and 72 per cent, respectively, of the total revenues received by the taxpayer in the 1982 and 1983 taxation years from manufacturing or processing (including "chrome applications”) for work described in categories (c) and (d). ...

Although we think that the explanation of the case by Lord Sumner in the Egyptian Delta case [1929] AC 1; 98 LJKB 1; 140 LT 50; sub nom Todd v Egyptian Delta Land & Investment Co, Ltd, 14 TC 119: Digest Supp produces, in effect, that result, nevertheless, the passage which we have cited above from Lord Cave’s speech seems to us to show that, in his opinion, residence in England could be supported, though the “central control and management’’ was concentrated in Sweden. ... They said: *... Clearly someone has a duty to do something about this absurd and unjust situation. ...