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Johnston states that either on March 29 or March 30, he caused the three beneficiaries, (his wife & two children, who at the time were four and five years of age) to execute the elections. ...

Subsection 125(1) of the Income Tax Act reads as follows: Small Business Deduction 125. (1) There may be deducted from the tax otherwise payable under this Part for a taxation year by a corporation that was, throughout the year, a Canadian-controlled private corporation, an amount equal to 25% of the least of (a) the amount, if any, by which (i) the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canada, exceeds (ii) the aggregate of all amounts each of which is a loss of the corporation for the year from an active business carried on in Canada, (b) the amount, if any, by which the corporation’s taxable income for the year exceeds the aggregate of (i) 10/4 of the aggregate of amounts deducted under subsection 126(1) from the tax for the year otherwise payable by it under this Part, and (ii) 2 times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable by it under this Part, (c) the corporation’s business limit for the year, and (d) the amount, if any, by which the corporation’s total business limit for the year exceeds its cumulative deduction account at the end of the immediately preceding taxation year, except that in applying this section for a taxation year after the 1972 taxation year, the reference in this subsection to “25%” shall be read as a reference to “24% for the 1973 taxation year, “23% for the 1974 taxation year, “22%’’ for the 1975 taxation year, and “21 %” for the 1976 and subsequent taxation years. ...

Until further notice the Trustees of the Plan shall be those named in an Agreement dated February 26th 1965 — between the company and the Trustees. ...

There is one minor exception — Muzly Lawee acquired a 17 /2% interest in land bought by Ezra Lawee and Sossoon Abed in St Laurent in conjunction with them and two of her daughters. ...

Price, Waterhouse & Co., Chartered Accountants disclosed that after paying the liabilities of Wenonah (including a debt of $367,858.10 owing to the deceased) there were available for distribution to the shareholders on the dissolution of Wenonah assets having a market value of $117,977.71 (which calculation is based on the valuation of a residential property owned by Wenonah at $102,000.00 being the appraised value of such property in 1967 when Wenonah acquired the said property), of which pursuant to the Letters Patent of Wenonah the estate of the Deceased as the beneficial owner of 2,000 Class B shares was entitled to receive $2,000.00 and the holders of the Class A shares were entitled to receive the balance of $115,977.71. 18. ...

Avagliano, 457 U.S. 176 (1982). 1 ’Joint Book of Documents, (the "Book") Exhibit 1, Tab 18 at sheet 9 of the document and page 208 of the Book (February 2, 1982). 2 1982)^ k 26 ^ 4 of the d° and page 219 of the Book (March 9, 3 Ibid., tab 30 at page 8 of the document and page 236 of the Book (May 12, 1982). 4 Ibid., tab 33 at sheet 4 of the document and page 250 of the Book (June 8, 1982). 5 1982)^ b 35 at ^ 5 of the d° and page 259 of the Book (August 4, 6 198 tab 35 at sheet 5 of the document and page 259 of the Book (August 4, 7 Ibid., tab 35 at sheet 8 of the document and page 262 of the Book (August 4, 1982). 8 Joint Book of Documents, Exhibit 2 at page 1279. 9 M.C.A. ...

The defendant argues (refer paragraph 18 of the statement of defence) that the golf course operation should be characterized as "an adventure in the nature of a trade” and that once that is done, then, generally accepted accounting principles should be applied to require the plaintiff to deduct all expenses incurred with respect to the venture as expenses for the year in which the property was disposed of ("the year in which the adventure was completed") — in this case 1979. ...