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PHILLIPS & VINEBERG Per: Philip. F Vineberg, Solicitor for the Appellant DATED AT MONTREAL, this 17th day of November 1977. ... In the words of Thurlow, J in McMahon v MNR, [1959] CTC 166 at 171; 59 DTC 1109 at 1111: “... ...

One statement to this effect is found in the judgment of Thurlow, J, as he then was, in the Court of Appeal in the case of MNR v Yonge- Eglinton Building Limited, [1974] FC 637 at 653; [1974] CTC 209 at 219;* 74 DTC 6180 at 6187, where he states: Principal Interest Total Total (a) November 28th, 1968 660,000.00 — 660,000.00 (b) July 20th, 1969 311,169.00 14,031.19 325,200.19 (c) August 25th, 1970 233,101.00 28,431.74 261,532.74 (d) October 4th, 1971 597,377.00 119,262.60 716,639.60 $1,801,647.00 $161,725.53 $1,963,372.53 No witnesses were called.... ... Reference was also made to the case of Raja’s Commercial College v Gian Singh & Co Ltd, [1977] AC 312, in which the Simpson v Executors of Bonner Maurice and Riches v Westminster Bank Ltd cases (supra) were discussed in detail. ...

The Minister assessed the company to sales tax on the basis that the processed marble constituted “goods produced or manufactured in Canada” under paragraph 30(1)(a) of the Excise Tax Act, RSC 1952, ¢ 100. ... It was stated in this way by Parke, B (Becke v Smith (1836), 2 M & W 191 at p 195): “it is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used, and to the grammatical construction, unless that is at variance with the intention of the legislature, to be collected from the statute itself... ...

According to Schedule 1 attached to the notice of assessment, that figure was arrived at as follows: Sale of land $2,307,330.00 Cost of land in 1960 $393,666.00 Capitalized carrying charges — 1960 to 1972 148,257.00 $ 541,923.00 1972 taxable income $1,765,407.00 Counsel for the plaintiff took two broad positions: (1) that the plaintiff’s dealing with the realty was not an adventure in the nature of trade, the submission being that it was acquired as an investment which resulted in a capital gain; (2) that the plaintiff was neither a resident of Canada nor a nonresident which carried on business in Canada and so was not taxable. ...

In 1953 he purchased the assets owned by the 1935 company from the estates of the then deceased original partners and shareholders and incorporated a new company under the name of McCallum Hill & Co Limited (hereinafter referred to as McCailum Hill) to continue the business of the former company. ... Prior to this event Mr Hill had commissioned Larry Smith & Co of Seattle, Washington, a firm of real estate consultants who also describe themselves as economic consultants, to prepare a brochure of the proposed shopping centre including a site plan of the centre showing the location and description of retail outlets and a drawing of the centre, both prepared by H K Black, an architect in Regina engaged by Mr Hill to do this, a plan of the development the same as the general Outline Plan approved by the City Council on December 23, 1957, which was a year subsequent to the completion of the brochure in December 1956, to demonstrate the accessability of the site, a review of the trade area to be served, the income and buying power of the residents of that area, the sales potential and the prospect of increase therein and a comparison of the Hillsdale site with competing sites. ...

It further maintains that the building should be classed in Class 3, and the lessee rights in Class 13, by virtue of the decision in Cohen & Zalkind v MNR, [1967] CTC 254; 67 DTC 5175. ... One of these letters (similar to those written to other tenants) was sent to Messrs Paquette & Paquette, one of the tenants, and reads as follows: Dear Sirs: Since acquisition of the Transportation Building by our subsidiary company, some tenants have inquired with some concern as to our plans for this building. ...

E-15, as amended (“ Act ”). By letter dated September 28, 1987, an investigation agent from the Licensing Section- Fiscal Interpretations in Revenue Canada confirmed that, during his earlier meeting with Mr. ...

Working to earn, in the plaintiff’s philosophy, builds character, self-discipline, moral strength, perseverance and self-confidence — a commendable objective. ... If he guarantees nothing he cannot be found liable as a guarantor — a simply straightforward solution. ... Both Claude and Pauline Bouchard testified as to facts concerning the transaction which are compatible with the creation of a trust with themselves as beneficiaries and the plaintiff and his wife as the nominal owners, holding the title to the property as trustees for their benefit — all the essential elements of a trust. ...

He was carrying on his business under the name of Ken Allen & Sons Limited and was apparently the sole shareholder save for qualifying shares. ... Other certificates were also registered against Ken Allen & Sons Limited. ... Horses were entered in the show under the name Ken Allen and Sons — owner. ...

The refinery could not operate without water and, in particular, required water for four purposes: — as a coolant in the heat exchangers — as make-up water to the lube area cooling system — to produce steam in the utility plant — to fight fires 4. ...