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Canadian Security & Mobile Patrol Services Ltd. v. M.N.R., 2023 TCC 34 Dockets: 2019-3371(EI) 2019-3372(CPP) BETWEEN: CANADIAN SECURITY & MOBILE PATROL SERVICES LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent.   ... “Patrick Boyle” Boyle J.   CITATION: 2023 TCC 34 COURT FILE NO.: 2019-3371(EI) 2019-3372(CPP) STYLE OF CAUSE: CANADIAN SECURITY & MOBILE PATROL LTD. ... PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: March 13, 2023 REASONS FOR JUDGMENT BY: The Honourable Justice Patrick Boyle DATE OF JUDGMENT: March 22, 2023 APPEARANCES:   Agent for the Appellant: Hasan Shahid Counsel for the Respondent: Amin Nur   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     ...

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. ...

& V.) and Heppell & Bouchard Inc. (hereinafter referred to as H. ... The eight parties to the contract were as follows: — Heppel & Bouchard Inc.; — Robert Verrier & Fils Ltée; — La Royale du Canada, Cie d'assurance; — La Compagnie d'assurance du Québec; — Gestions H. & B. Ltée; — Les Placements Claude Bouchard; — Claude Bouchard; — Michel Verrier. ...

If the framers of the Regulation had intended to mean the business itself, they would have used the word " thereby " or " by it " rather than the word " therein ", which latter word conveys the sense of being inside something physical. In the same vein the word " therein " can hardly apply to personnel. ... " is a hairdressing salon operating in the City of Edmonton ". ...

Ogulnik & Co. Ltd., [1928-34] CTC 274 TELLIER, C.J.—The following is the provision of the Special War Revenue Act, R.S.C. 1927, c. 179, sec. 86 on which the plaintiff relies:— " 1 86. ... This would be sufficient to dispose of the case, if the Minister of National Revenue had not, in the exercise of the power conferred upon him by sec. 95 of the said Special War Revenue Act, enacted a regulation which the defendant invoked, the text of which is as follows:— "‘(11) Merchant tailors, dressmakers, milliners and florists selling exclusively by retail to the consumer or user are classified as retailers and are not required to take out a Sales Tax License. ‘ " The terms ‘merchant tailor ‘ and ‘ dressmaker ‘ in this regulation means the ordinary merchant and the ordinary dressmaker who fits, makes and sells his goods to the order of the individual customer on the same premises upon which they are made and not through agents or chain of stores.’’ ... The following is the state of the total sales in bulk, and by retail for each one of the five years in question:— Year Retail Bulk 1924 $71,953.51 $ 65,000.11 1925 65,455.61 104,967.11 1926 • 72,149.93 125,692.72 1927 72,571.56 136,539.26 1928 69,164.42 169,328.83 $391,285.08 $601,528.03 As may be seen, the wholesale business exceeded that by retail considerably. ...

Attorney General of Canada / Re Claim, under s. 1036 of the Criminal Code, to certain fines, [1937] S.C.R. 403 Supreme Court of Canada Attorney General of Nova Scotia v. ... The matter is now referred to us under section 43 of the Supreme Court Act, in view of the fact that, by section 6 of chapter 226 of the Revised Statutes of Nova Scotia, 1923, the opinion of the Supreme Court of Nova Scotia upon the reference, although advisory only, is, for all purposes of appeal to this Court, to “ be treated as a final judgment of the court between parties.” ... It is contended by the Attorney-General of Canada that they were “ imposed in respect of the breach of any of the revenue laws of Canada,” and that they were “imposed * * * in a proceeding instituted at the instance of the Government of Canada or of a department thereof in which that Government bore the cost of prosecution.” ...

That where any stockbroker, acting either as principal or agent, effects the sale of a taxable security by means of a transaction which is not executed on a stock exchange in Canada, the tax exigible on the transaction is to be paid to the Crown by the vendor stockbroker affixing excise tax stamps of the requisite value to the duplicate of the memorandum of sale retained on file in his office. ‘ ‘ (12. ... These regulations were subsequently rescinded with effect from 1st June, 1937, by the order of the Governor-in-Couneil and the following regulations substituted therefor:— " " 2. ... Thus I must conclude that since by statute, sec. 60, the duty is payable by the vendor of the " " security ’ ’ in excise stamps, it must be assumed that the stamps were purchased by the defendants as voluntary agents of the vendors and thus that the stamps originally came into possession of the defendants as agents of the vendors of the securities. ...

In those reassessments, the Minister levied the following federal penalties: Taxation Date of Year (Re)Assessment Penalties 1971 24 November 1977 $ 80.75 3 March 1978 $1,481.96 24 May 1979 $ 100.83 1972 24 November 1977 $ 631.23 3 March 1978 $ 822.83 24 May 1979 $ 643.85 1973 24 November 1977 $2,789.09 3 March 1978 $4,451.77 24 May 1979 $2,948.87 1974 24 November 1977 $2,570.56 3 March 1978 $3,460.75 24 May 1979 $2,681.11 1975 24 November 1977 $ 543.08 3 March 1978 $ 970.01 24 May 1979 $ 580.19 (k) The Appellant appropriated to his own benefit unreported revenue of MidNorth in the amounts of $2,807.41, $11,573.36, $18,402.72 and $900 respectively in his 1972, 1973, 1974 and 1975 taxation years. ... The same two persons (/ and plus Alan Hill (were partners in NIM Disposals. ... March 12 1973 5815 $ 1,229.30 BG; BL 2. March 26 1973 5861 2,000.00 BG; BL 3. ...

The names of four persons who, on January 24, 1967, resigned as officers and directors of Vineland and the positions which they held with Vineland at the time of their resignations were as follows: Benjamin Sauder — president and director Shirley Sauder — treasurer and director Samuel Taylor — vice-president and director E. ... Goodman & Carr. Mr. Franklyn E. Cappell of this firm had, however, written to Mr. ... Goodman & Carr. I intend to grant the present application and to hold Messrs. ...

COURT FILE NO.:                                                 2000-3982(EI) and 2000-3984(CPP) STYLE OF CAUSE:                                               Sara Consulting & Promotions Inc. v.                                                                                 ... Bell DATE OF JUDGMENT:                                       November 20, 2001 APPEARANCES: Counsel for the Appellant:                  Carman P. McNary Counsel for the Respondent:              Margaret McCabe COUNSEL OF RECORD: For the Appellant:                 Name:                Carman P. ...