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Accordingly C T Loewen & Sons (1957) Ltd was incorporated to operate the business. This company purchased the business from C T Loewen & Sons Ltd and acquired the inventory. ... Meanwhile the worth of the operating company, C T Loewen & Sons (1957) Ltd, had increased to $400,000. ...

Deloitte & Touche Inc., the Trustee of the Estate of Vancouver Trade Mart Inc., a Bankrupt v. Attorney General of Canada Representing the Minister of National Revenue, [1996] 3 CTC 357 Rouleau J.: — This Applicant came before the Court on August 27, 1996, seeking an extension of time to file its motion record. ...

Pipe & Piling Supplies LTD v. Her Majesty the Queen, [1979] CTC 445, 79 DTC 5364 Cattanach, J:—For reasons similar to those expressed in the motion in Mike Dym and The Queen (Court File No T-64-77) the motion herein is likewise refused. ...

Deloitte Haskins & Sells, Receiver-Manager for Comanche Drilling Ltd. v. ... Coopers & Lybrand Ltd., [1981] 2 F.C. 169; [1980] C.T.C. 367, 406; 80 D.T.C. 6281. A detailed analysis of the Coopers & Lybrand case is essential before arriving at a decision. ...

Plan € Leasing Limited v. Her Majesty the Queen, [1976] CTC 271 Gibson, J:—For the reasons given in the case of Plan A Leasing Limited v Her Majesty the Queen (Court No T-2224-75) this date, this appeal is allowed with costs, and the matter is directed to be referred back for reassessment not inconsistent with the reasons. ...

The Clarkson Company Limited, the Receiver and Manager of the Property and Undertaking of Rapid Data Systems & Equipment Limited v. ... In N W Robbie & Co, Ltd v Witney Warehouse Co, Ltd, [1963] 3 All ER 613, the Court held that there was no mutuality and therefore no right to set off, but the debt in question had come into existence after the appointment of a receiver. ... Kay, LJ said at page 105: Then it was urged that this claim could not be asserted against the debenture-holders, who had a charge on all the property of the company, inasmuch as Harvey, Brand & Co knew of the debentures. ...

Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180, [1989] 1 CTC 417 (FCTD) Dubé, J. ... Nelson Rudelier is also involved in the real estate business and is the sole owner of a holding company, the defendant Rudelier Ranches & Livestock Company Ltd., incorporated in 1973. ... RUDELIER RANCHES & LIVESTOCK COMPANY LTD. (plaintiff) 100% owned by Nelson Rudelier Date of Purchase Date of Sale (1) 540 Helmcken St. ...

R & W Such Holdings Ltd., [1996] 1 CTC 53, 95 DTC 5512 Hargrave P.— This motion, in writing pursuant to Rule 324, is brought by the Crown to strike out the plaintiff’s statement of claim for want of prosecution or, alternatively, by reason of the failure of the plaintiff to provide an affidavit of documents. ... McAlpine (Sir Alfred) & Sons Ltd., [1968] 2 Q.B. 229, 1 All E.R. 543, at page 268-69 (All E.R. 561): 1. ... It would be highly undesirable and indeed impossible to attempt to lay down a tariff — so many years or more on one side of the line and a lesser period on the other. ...

Oriole Oil & Gas Ltd. v. M.N.R., [1991] 1 CTC 307 Martin J.:—The issue in this matter is whether the sums of $500,000 paid by the plaintiff, Oriole Oil & Gas Ltd., Ç Oriole") to each of its two shareholders/ employees were sums paid to discharge the company's liability under bona fide employment contracts between the two, Herbert Charles Flanagan (” Flanagan”) and Larry Ross Burroughs (“ Burroughs") for their prospective loss of employment or office, or were they in fact and in substance a part of the consideration for the sale by Flanagan and Burroughs of their shares in Oriole to Alberta Eastern Gas Ltd. ('A.E.G. ... Flanagan’s contract, identical to Burroughs’, which counsel for Oriole himself described as “ bizarre”, although purporting to be made effective May 1, 1972, was not in fact signed until early 1974. ... I am in agreement with the Tax Court judge when he observed that a similar claim made by Flanagan before him that the employment contracts were entered into for monetary protection ” rings hollow". ...

Byrdys & Worms Enterprises Inc. v. Minister of National Revenue, [1998] 1 CTC 135 Nadon J.: UPON MOTION, dated the 1st day of October, 1997, on behalf of the Applicant, pursuant to Rules 344 and 1618 of the Federal Court Rules, for: a) an Order that the Respondent pay to the Applicant costs on a Solicitor/Client basis, or on such other basis as might be found by the Court to be reasonable. ...