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.: — The appellant appeals from assessments of income tax for the 1991, 1992 and 1993 taxation years. ... He held the view that a business plan was a document usually required to induce a financial institution into loaning start-up money and, since he was going to rely entirely on his own resources, he did not feel a written plan was necessary. ... It was a 2- axis machine in which he used a software program — basically a motion control card- that he had purchased and then programmed code to meet his specific needs. ...

I cannot, therefore, find — nor would I find on the evidence before me — that Mr. ... The provision embraces a subjective element which takes into account the personal knowledge and background of the directors, as well as his or her corporate circumstances in the form of, among other things, the company’s organization, resources, customs and conduct. ... Giglio owned 50 per cent of the shares of Patersil. 2 /?. v. Giglio, [1997] 2 C.T.C. 2608 (T.C.C.); order issued February 21, 1997. 3 (1988), 88 D.T.C. 1531 (T.C.C.) 4 Subsection 121(2) states that “a resignation of a director becomes effective at the time a written resignation is received by the corporation...” 5 Appellant’s counsel, Mr. ...

Everett does not appear to have had the resources to pay the indebtedness under the note and this obligation was therefore guaranteed by Polar Oils Ltd. ... Since he did not have the resources to pay the instalments, Polar Oils Ltd. did so from the outset by paying the appellant who in turn paid Mel's Truck Stop Ltd. ... Had Polar paid the appellant the sum of $119,658 as the price of its committment and had the appellant paid Mel’s Truck Stop Ltd. the same amount, the use made by the appellant of the funds could not have altered the nature of the receipt in the appellant’s hands — a receipt for a commitment integrally bound up with its day-to-day business and having the quality of income. ...

The usual rule — and I see no reason why it should not apply in income tax appeals — is set out in Odgers’ Principles of Pleading and Practice, 2nd edition at page 532: The “burden of proof” is the duty which lies on a party to establish his case. ... For the reasons given in Mark Resources Inc. v. R. (sub nom. Mark Resources Inc. v. ...

The Appellant was incorporated under the laws of Ontario on May 31, 1982, and at all material times herein carried on the business of exploring for, developing and mining mineral resources in Canada. 2. ... At all material times herein the business of Highmont was the exploration, development and mining of mineral resources in the Highland Valley region of British Columbia. ... Davie & Sons Ltd. v. Minister of National Revenue, [1954] C.T.C. 124, 54 D.T.C. 1045 (Exch.); and J.D. ...

McGee stated that he did not know how the figure of $400 million was chosen but that the amount could be met out of Husky’s cash resources. [20] [41] Mr. ... Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (“ Alta Energy ”) at paragraph 185. ... Canada, 2005 SCC 54 (“ Canada Trustco ”), Lipson, Copthorne Holdings Ltd. v. ...

The principle was best expressed by MacGuigan, J.A. in West Kootenay Power & Light Co. v. ... [Emphasis added.] 9 See also for instance West Kootenay Power & Light Co. v. ... West Kootenay Power & Light Co. v. Canada), [1992] 1 C.T.C. 15, 92 D.T.C. 6023 (F.C.A.) and Maritime Telegraph & Telephone Co. v. ...

Janzen, Director of Human Resources as well as Director of Administrative Services and Ed Sider, Director of Program Services. ... R. (1983), 83 D.T.C. 5041 (S.C.C.), at 5045 in a different context, “... too fine a distinction for my liking.” ... The work of the parties who did not testify was described by very credible witnesses — Messrs. ...

:—The appellant appeals from the assessments for its 1981, 1982,1983 and 1984 taxation years, whereby the Minister of National Revenue (the “ Minister”): (a) reclassified property acquisitions claimed by the appellant as being assets of the category of Class 29 of Schedule II of the Income Tax Act Regulations (the “ Regulations”), used directly or indirectly by the appellant principally in the manufacture or processing of goods for sale or lease into assets of the category of Class 8 of Schedule Il of the Regulations; (b) limited inventory allowances claimed by the appellant under paragraph 20(1)(gg) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... An examination of the various contracts, such as those with Noranda Exploration Co., Teck Exploration Ltd., Falconbridge Ltd., Esso Minerals Canada, a Division of Esso Resources Canada Ltd., and Cominco Ltd., shows that Midwest was providing drilling services and that with a few exceptions the charges to the client by Midwest were for these services. ... (B) the least of the amounts determined under paragraphs 125(1)(a) to (d) in respect of the corporation for the year, (C) two times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable under this Part by the corporation, and (D) the amount, if any, by which the aggregate of the corporation's Canadian investment income for the year and its foreign investment income for the year (within the meanings assigned by subsection 129(4)) exceeds the amount, if any, deductible under paragraph 111(1)(b) from the corporation’s income for the year; and 125:1(3)(a) “ Canadian manufacturing and processing profits" of a corporation for a taxation year means such portion of the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada as is determined under rules prescribed for that purpose by regulation made on the recommendation of the Minister of Finance to be applicable to the manufacturing or processing in Canada of goods for sale or lease; and (b) manufacturing or processing" does not include (x) any manufacturing or processing of goods for sale or lease, if, for any taxation year of a corporation in respect of which the expression is being applied, less than ten per cent of its gross revenue from all active businesses carried on in Canada was from (A) the selling or leasing of goods manufactured or processed in Canada by it, and (B) the manufacturing or processing in Canada of goods for sale or lease, other than goods for sale or lease by it. ...

Franchising was started because it was difficult for JCCL to open stores from its own resources and Noritsu insisted on increased sales and these sales could be effected by granting franchises and selling equipment to the franchisees. ... In support of this, counsel for the appellants refer to Front & Simcoe Ltd. v. ... The Queen, [1985] 2 C.T.C. 79; 85 D.T.C. 5310 (F.C.A) and Versatile Machine & Tool Manufacturing Co. v. ...