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Point Grey Golf & Country Club v. R., [1997] 1 CTC 2721, 97 DTC 854 Archambault J.T.C.C.: — These are appeals by Point Grey Golf & Country Club (“Point Grey”) from reassessments for income tax by the Minister of National Revenue (“Minister”) in respect of the 1989, 1990 and 1991 taxation years (“relevant taxation years”). ... Its by-laws provided that the objects of Point Grey was to conduct a golf and country club on the premises owned by Point Grey Golf & Country Club Limited. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) Rip J.T.C.C. — The main issue in these appeals [1] is whether a certain outlay is an expense incurred in the course of carrying on a business and is deductible in determining the appellants’ income from business for the year in accordance with section 9 of the Income Tax Act (“Act”). The facts in the appeals of 212535 Oil & Gas Ltd., 212634 Oil & Gas Ltd., 212873 Oil & Gas Ltd. and 228262 Alberta Ltd. from income tax assessment for their 1981 taxation year [2] are similar, if not identical, to those in the appeal of St. ... Ives, supra, was whether the sum of $1,250,000 which that taxpayer had agreed to pay Carter Oil & Gas Ltd. ...

Supermarché Dubuc & Frère Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2215 (Informal Procedure) Garon, J.T.C.C. ... Dubuc stated that he began operating a grocery business on July 1, 1973 under the trade name Dubuc & Frères Enr. ... In the instant case the payment made by Métro-Richelieu was made to induce the taxpayer to conclude the fidelity agreement: — This payment was not associated with the purchase of property, whether equipment, rental improvements or otherwise. — This payment was not associated with expenses incurred or to be incurred by the taxpayer. — The taxpayer had absolute control over the amount received. — The taxpayer was not required to use the said amount for specific purposes. ...

Hansen & Sons Construction Ltd. (Hansen Construction) with respect to its 1979 taxation year. ... His evidence as to the appellant’s trading history can be summarized as follows: 1. 1976 — The appellant purchased the Schnell & Barrie Building. ... The acquisition of the Schnell & Barrie building had been a profitable exercise. ...

Apl Oil & Gas Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2001 Margeson J.T.C.C.: — The Appellant filed an appeal from the reassessment dated August 14, 1991, number 3532072, with respect to its taxation year ending January 2, 1987. ... Attached herewith as Exhibit “B” is a copy of the August 17, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 7. ... Attached herewith as Exhibit “C” is a copy of the September 22, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 8. ...

James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC) Christie, A.C.J.T.C.: —This appeal relates to the appellant's 1983 taxation year. ... The form of notice of forfeiture sent by mail to a pawner by the appellant reads: DEAR SIR or MADAM: — Your Loan No. of For$ is past due. ... Very truly yours, JAMES MCTAMNEY & CO. LTD. THIS LOAN COVERS Interest & Storage due. ...

Tubetest Service & Supply (1978) Limited, v. Her Majesty the Queen, [1994] 2 CTC 2320 O'Connor J.T.C.C. ... Chequing nil $ 2,375 Rec. General $ 998 $4,136 3. Only 20 per cent of the term deposits was used as security on outstanding bank loans with regard to the main business; 4. ... The company chose to reduce its taxable income to $200,000 by paying directors' and management fees and having the shareholders and management pay income taxes at high personal tax rates rather than have Tubetest Service & Supply (1978) Ltd. pay high corporate tax rates on taxable income over $200,000. ...

They are: (a) the existence of a common mind which directs the bargaining for both parties to the transaction, (b) parties to a transaction acting in concert without separate interests, and (c) " de facto " control. ... " [31] This approach was also adopted by Cullen, J. in the case of Peter Cundill & Associates Ltd. v. ... Part 2 – Review of the Evidence as it relates to Kevin Sharp and Brian Sharp [88] I do not propose to review all of the evidence a further time. ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC) Bonner,T.C.J.: — The appellant appeals from assessments of income tax for the 1983, 1984 and 1985 taxation years. ...

B & M Carriers v. Her Majesty the Queen, [1993] 2 CTC 2801, 93 DTC 1205 Sarchuk, T.C.C.J. ... And in this case, what it permitted was the ability to pay over time out of profits — profits which would not be subject to or [sic] remittance to, Her Majesty — pay that to the creditors. ... Canada Employment & Immigration Commission, [1985] 2 S.C.R. 417, 23 D.L.R. (4th) 641; Beauchesne Inc. v. ...