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The facts in the appeals of 212535 Oil & Gas Ltd., 212634 Oil & Gas Ltd., 212873 Oil & Gas Ltd. and 228262 Alberta Ltd. from income tax assessment for their 1981 taxation year [2] are similar, if not identical, to those in the appeal of St. ... Ives Resources Ltd. Hence the appellants at bar are free to make that argument. ... LCR Resources Ltd. did not appear when its appeals were called. Counsel for the respon dent informed me she had received a letter from counsel for LCR Resources Ltd. stating that LCR Resources Ltd. agrees to be bound by the outcome of the appeals of the other appellants. ...

Signed at Ottawa, Canada, this 17th day of July 2003.     “Alain Tardif” Judge Tardif     Translation certified true on this 30th day of January 2004.       ...   [33]     The business was created, organized and operated in accordance with the available resources and following the applicable rules ...

Reasons for Judgment Hamlyn, J.T.C.C. [1]            This is an appeal with respect to an assessment under Part IX of the Excise Tax Act (the " Act ") for the period January 1, 1993 to February 29, 1996, by Notice of Assessment No. 01CB0202152 dated July 17, 1996. [2]            The Appellant is a corporation involved in the sale of new and used motor vehicles. [3]            Between 1994 and 1995, the Appellant sold 14 vehicles to one Vaughn Pictou ("Pictou"), a status Indian. ... Pictou indicating that GST was paid; 6(i)           at no time did Mr. ... In this same community, Pictou carried on a gas bar and convenience store business that produced, in the view of one witness, ample resources for Pictou to trade vehicles as he did. [17]          The best evidence as to whether the several vehicles purchased or traded by Pictou were part of a business of Pictou should have come from Pictou. ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC) Bonner,T.C.J.: — The appellant appeals from assessments of income tax for the 1983, 1984 and 1985 taxation years. ... (d) "active business” carried on by a corporation in a taxation year means the business of manufacturing or processing property for sale or lease, mining, operating an oil or gas well, prospecting, exploring or drilling for natural resources, construction, logging, farming, fishing, selling property as a principal, transportation or any other business carried on by the corporation other than a specified investment business, a non-qualifying business or a personal services business; (e) "income of the corporation for the year from an active business" means the income of the corporation from an active business carried on by it, including any income pertaining to or incident to that business and amounts deemed by subsection 129(6) to be income from an active business, but does not include income for the year from a source in Canada that is a property (within the meaning assigned by subsection 129(4.1)). ...

Simmonds & Sons Ltd. v. MNR, 89 DTC 707, [1990] 1 CTC 2087 (TCC) Christie, A.C.J.T.C.: —The notice of appeal and the reply thereto regarding this litigation relate to two issues. ... It had no financial history and inadequate financial resources to establish sufficient bank credit. ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1 Docket: 2017-4641(IT)G 2019-2446(IT)G BETWEEN: PROCON MINING & TUNNELLING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... The Business Plan described at the time as Resource Equity Investments, with Investment Value and providing long-term revenue and earnings. ... Canada (Minister of National Revenue — M.N.R.), [1967] 1 Ex. C.R. 245 at p. 257. ...

Gaudreau & Associés, Avocats, S.E.N.C. v. M.N.R., docket 98-59-UI Date: 19990507 Docket: 98-59-UI BETWEEN: GAUDREAU ET ASSOCIÉS, AVOCATS, S.E.N.C., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... I understand, I mean, that you don’t have any financial resources, you can’t pay rent, etc., so we’ll adjust things as we go along. ...

Apl Oil & Gas Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2001 Margeson J.T.C.C.: — The Appellant filed an appeal from the reassessment dated August 14, 1991, number 3532072, with respect to its taxation year ending January 2, 1987. ... On January 2, 1987 the Appellant amalgamated with Nasa Hydrocarbon Resources Ltd., a Canadian-controlled private corporation. 3. ... By letter dated September 22, 1987, Vennard Johannesen & Co., on behalf of the Appellant, requested that Revenue Canada make adjustments to the Return as a result of revised capital cost allowance claims, resource allowance calculations and investment tax credit claims, and specifically referred to the January 2, 1987 taxation year. ...

Installation Mécanique G & B Ltée v. Minister of National Revenue, [1987] 1 CTC 2326, 87 DTC 226 Tremblay, T.C.J. ... The work to be performed was as follows: repair "the hopper — building 310 in accordance with the sketch attached hereto and Mr. ... Act — Case Law — Analysis 5.01 Act The provisions chiefly involved in this case are paragraphs 125.1 (3)(a) and (b) of the Income Tax Act and section 5200 of the Income Tax Regulations. ...

(Braun & Associates) v. M.N.R., 2009 TCC 339       Docket: 2008-2955(CPP) BETWEEN:   6005021 CANADA INC. ... This interpretation is supported further by subsection 26.1(2) of the CPP which allows the Minister of Human Resources and Development to request a ruling at any time; all to say the Government can always overcome Mr. ...   [5]           2009 FCA 55.   [6]           2001 SCC 59.   [7]           2007 TCC 547 ...