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Following the same pattern, the four partners acquired additional property in the City of Montreal and suburbs as follows: (a) On October 25, 1955, Lots 105 and 106 in Pointe Claire — for a purchase price of $356,000, payable one-half in cash, and the balance payable in five equal annual instalments, interest at 5%. ...

In its 1963 balance sheet, appellant Joleen Investments Limited shows among current assets an amount of $21,615.11 as “inventory — land (at cost)”. ...

While the words “... shall receive tax treatment by Canada not less favorable than that accorded under Section 99...” are quite general, I am unable to construe them in any other way, and I hold the Article does so prevent. ...

This actual valuation was established on the basis of the valuation by three experts, one of whom, Mr Madison H Haythe, vice-president of the well-known investment firm of Morgan Stanley & Co, testified in Court. ...

I see no reason for so limiting the scope of the words in section 24, particularly the words authorizing the Minister at any time to “... assess, re-assess, or make additional assessments upon any persons... for duties, interest and penalties”. ...

The owners insisted on selling the whole of their properties, or none at all. 11 In order of date, the deeds of purchase, and the agreed sale prices, were as follows: Mary St Louis-- April 5, 1965-- $165,750 LaPorte-- May 20, 1965-- $ 35,000 James St Louis-- June 1, 1965-- $150,000 12 The transactions were ultimately paid in cash, except in respect of the James St Louis farm. ...

It is, as applied to this case, “... his income for the year from all duties performed by him in Canada...”. 14 As has been said over and over again, the statute does not define “income”. ...

DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT   ...

The plaintiff also alleges that by reason of further sales and deliveries of such equipment and supplies in the period from August 1, 1966 to the end of 1967 the company became further liable for sales tax at 12%, making a tax liability of $715.55, which the company neglected, failed or refused to pay (paragraph 5 of the Information); and that by reason of non-payment of that liability the company became liable to penalties that amounted to $159.79 to April 30, 1970 (paragraph 6), In the Information the plaintiff alleges that the amounts remaining unpaid and owing to Her Majesty by the defendant were: Penalties to August 12, 1968, $ 602.10 Tax unpaid 715,55 Penalties on said tax to April 30, 1970 159.79 Total $1,477,44 and the plaintiff claims: (a) payment of that sum of $1,477. 44: (b) payment of additional penalties and interest accruing under the Act, until judgment; (c) costs. ...

He adds that “construing the words ‘at any time’ literally and out of context means the Crown could commence proceedings today to collect tax due on a transaction back in 1915 — clearly an unreasonable result.” ...