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TDX Exploration & Mining Ltd. v. R., [1999] 4 CTC 148, 99 DTC 5405 Reed J. ... Revenue Canada (Customs, Excise & Taxation) (1996), 96 D.T.C. 6347 (Fed. ...

L & M Wood Products Ltd, North Battleford Lumber and Post Sales LTD and Glaslyn Forest Products LTD v. ... The plaintiffs L & M Wood Products Ltd and North Battleford Lumber and Post Sales Ltd are appealing their income tax assessments by the defendant for the taxation years 1968 and 1969. ...

Tom Baird & Associates Ltd., [1997] 1 CTC 86 McKeown J.: — The plaintiff, Her Majesty The Queen, appeals the decision of the Canadian International Trade Tribunal (CITT) allowing an appeal of the defendant, Tom Baird & Associates Ltd., from certain Notices of Determination of the Minister of National Revenue. ... LR.C., [1971] A.C. 739 at page 746 (H.L.): Secondly, “... one has to look merely at what is clearly said. ...

Orenstein & Partners Inc. In Its Capacity as Court-Appointed Receiver of the Part Viii Tax Refund of Scannar Industries Inc. ... The plaintiff, Orenstein & Partners Inc. (Orenstein), is the Court-appointed receiver of the Part VIII tax refund allegedly owing to the other plaintiff, Scannar Industries Inc. ... Finally, the plaintiffs argue that the decision of the Associate Senior Prothonotary was based on the view that the defendant's objections are based on the notion of estoppel — that is that the plaintiffs are estopped from relying on the application of subsection 194(4.2) — and that this is an argument that should more properly be considered by the trial judge (Plaintiffs’ Outline, supra, paragraphs 10 and 23). ...

Handy & Harman of Canada Ltd. v. MNR, 73 DTC 5401, [1973] CTC 507 (FCTD) Heald, J:—This is an appeal from a reassessment by the respondent of the appellant’s income tax for the taxation year ended December 31, 1967. ... The market price for silver is announced each day at noon, by Handy & Harman, appellant’s parent company, in New York. ... This table reads as follows: HANDY & HARMAN OF CANADA LIMITED SILVER PRICES AND VALUES 1946—JUNE 1967 $ PER OZ. ...

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD) Dubé, J:—These are appeals from reassessments made by the Minister of National Revenue for the taxation years 1966, 1967, 1968, 1969, 1970 and 1971. ... The English Court of Appeal in Commissioners of Inland Revenue v Alexander Von Glehn & Co, Ltd, 12 TC 232, disallowed the deduction of a compromise penalty paid by the respondent company in respect of alleged infringements of the Customs (War Powers) Act, 1915, 5 Geo V, c 31. ... In the case of Minister of Finance v Smith, [1927] AC 193; [1917-27] CTC 251, wherein it was held that upon a literal construction of the Act the profits in question, though by law of the particular province they are illicit, come within the words employed in Section 3(1), Lord Haldane in his remarks said at page 197, in fine [[1917-27] CTC 254]: “... ...

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). ... Willson, the chartered accountant with the firm of Clarkson Gordon (now Ernst & Young), who was responsible for auditing the plaintiff's books. ... There was some suggestion in the presentation of this case that the concept ” reserve for doubtful debts" found in paragraph 20(1)(l) of the Act is different from the concept ” reserve for doubtful accounts" used in the preparation of financial statements, because the terminology in which each is expressed differs. ...

Block Research & Development (1981) Corp. v. MNR, 87 DTC 5137, [1987] 1 CTC 253 (FCTD) Dubé, J. ...

Vaughan’s Moving & Storage Co Ltd, and Keith Vaughan v. Her Majesty the Queen as Represented by the Minister of National Revenue, [1984] CTC 333 The Associate Chief Justice:—This action came on for trial at Yorkton, Saskatchewan, on October 4, 1983. ...

On December 21, 1965 the appellant issued the following cheques to the various trusts: President’s trust $46,726 Secretary’s trust 54,346 Vice-president’s trust 30,680 Total — $131,752 These cheques were negotiated by the three trusts and the proceeds deposited in bank accounts in the names of the three respective trusts. ... The Minister’s action in assessing the appellant for the taxation years under review can be expressed in summary form as follows: Amount Contri Amount allowed buted to Fund as a deduction Amount Year by Appellant by the Minister Disallowed 1965 $131,752 $ 3,752 $128,000 1966 9,991 3,691 6,300 1967 9,991 3,891 6,100 $151,734 $11,334 $140,400 The sums of $128,000, $6,300 and $6,100 which were disallowed by the Minister represent the amounts expended by the trusts in the respective taxation years to acquire Class “B” preferred shares of the appellant. ... The amount of pension is provided in paragraph 2.3 as follows: Amount of Pension The Annual Pension payable to a Participant shall be as follows; — (a) For each year of service subsequent to his date of entry into the Plan, each Participant will receive an annual pension equal to 2% of the average of the best six years earnings in the employ of the Company less any pension being purchased in respect to such service by the Company, and by any other registered pension plan of the Company. ...