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., Graham Excavating & Equipment Ltd., Sawyer Building Supplies Ltd., McKinney Plumbing & Heating Ltd., Cyprus Building Products Ltd., Higgs Cement & Masonry Ltd., Polar Electric Ltd, Chappell Concrete & Masonry Service Ltd. v. ...

Howson & Howson Limited and Howson & Howson Co. (Cargill) Limited, [1970] CTC 36, 70 DTC 6055 CATTANACH, J. ... Howson 900 — William F. Howson (a son of W. Fred) 900 — Douglas Howson (a son of W. ... These three companies, Howson & Howson Limited, Howson & Howson (Cargill) Limited and Howson & Howson (Wingham) Limited carried on business until 1956. ...

Julius Kayser & Co. Ltd. v. Minister of National Revenue, [1938-39] CTC 334 ANGERS, J. ... Asked if the parent company furnished the appellant with any other services, the witness replied: " " very little. ’ ‘ The advances made to the parent company by the appellant are entered in the latter’s book in a current account in the name of Julius Kayser & Company, New York. It seems to me expedient to cite here a passage from Mutchler's testimony concerning this account: Q. * * * And in that current account Julius Kayser, New York, is credited with the purchase of raw silk made on your behalf? ...

Manitoba Dairy & Poultry Co-Operative Ltd. v. Minister of National Revenue, [1957] CTC 400, 57 DTC 1278, [1957] CTC 401 THORSON, P. ... At this time we are pleased to advise you that your additional payments based on the savings realized by your Association are as follows: Lbs of Poultry shipped in 1947 @ 2. 52% —$ 8.97 “ “ “ “ 1948 @4.94%—$18.46 u u H 1949 @1.24%—$ 5.57 These will be paid out in accordance with our By-laws, subject to the approval of our members at each General Annual Meeting. ... The other headings were "" Credit to Share Acc’t”, $4.30 and “ “ Patronage Dividend”, $4.31. ...

McTaggart, Hannaford, Birks & Gordon Limited v. Minister of National Revenue, [1952] CTC 385, 52 DTC 1218 THORSON, P. ... He contended that the omission of the words made no change in the law and that the ‘ ‘ losses ’ ’ that were deductible under Section 5(p), as it stood after the deletion of the words, were business operation losses just as they had been previously. ... In view of the wording of section 3(1) of the Act which provides among other things, that ‘ "income'"... includes... dividends...’, it is impossible for me to accept this proposal. ’ ’ The Board dealt with the matter again in Smith, Davidson and Wright Limited v. ...

Western Leaseholds & Western Minerals v. Minister of National Revenue, [1958] CTC 257, 58 DTC 1128 CAMERON, J. ... A.— Loans. ’ ’ Then as a result of undertakings given at the examination for discovery to produce further information, Mr. ... By a letter-agreement dated December 31, 1947 (Exhibit 19) between Minerals and Leaseholds, it was agreed that Leaseholds should retain the $250,000 option money paid by Imperial and that in respect of the Imperial agreement, Minerals would grant to Leaseholds an exclusive option to purchase from time to time up to 7 per cent of its royalty on the following basis: Per acre On the first 10,000 acres $2.63 for each 1% purchased '' 66 second 7 “ PA 10 é¢ “ “ ‘ ‘ [ar 4 third [ar {C 1.58 '' [4 H “ ** balance of acreage 1.05 “ “ “ The only clear evidence relating to these payments of $34,850.18 and $199,544.55 is found in a paragraph of Exhibit 32—an agreement between Minerals and Leaseholds dated December 30, 1950, and called ‘‘An Agreement of Settlement and Adjustments’’. ...

The amount of this bid or " " bonus, ‘ ‘ as it was called, was not returned to the licensee. ... The Respondent argued that in fact this " " license ‘ is actually nothing more than a sale of goods and in support of that contention he referred to Marshall v. ... ‘ ‘ These decisions however were made before the passing of the Sale of Goods Act. ...

B & B Royalties, Ltd. v. Minister of National Revenue, [1940-41] CTC 65 MACLEAN, J. ... By an agreement (hereinafter referred to as ‘‘the Trust Agreement”) dated July 8, 1936, and made between the Company, therein called the " ‘ Operator, ‘ ‘ and The Security Trust Co. ... I have not been satisfied that the assessment should have been made against the Company and the owners of royalty interests, as an "‘associa- tion ‘ ‘; at least I presently entertain serious doubts as to whether this could be done successfully. ...

In the Shorter Oxford English Dictionary, 2nd Ed., “political” is defined as ‘‘of, belonging or pertaining to, the state, its government and policy ’ ’ and * " concerned or dealing with politics or the science of government’’. in the same value, "‘subdivision’’ is defined as "‘one of the parts into which a whole is subdivided; part of a part; a section resulting from a further division’’. ... The government, conduct, management and control of the University and of University College, and of the property, revenues, business and affairs thereof, shall be vested in the Board. ‘ ‘ Exhibit 1 is The University Act, R.S.O. 1937, ¢. 372. ... In considering the powers of that Board, Lord Haldane said: " " They are a body with discretionary powers of their own. ...

Stewart & Morrison Limited, [1970] CTC 431, [1970] DTC 6295 KERR, J. ... The so-called New York office was Stewart & Morrison Inc. a wholly owned subsidiary of the respondent. ... The letter states: In response to your request we are pleased to submit below a record of amounts received by Stewart & Morrison, Inc. from Stewart & Morrison Limited as capital contributions and loans payable. ...