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Andrew Paving & Engineering Ltd, Meld Development LTD v. Minister of National Revenue, [1984] CTC 2164, 84 DTC 1157 Christie, CJTC:—The issues on these appeals are the same. ... Land & Tbr. Co. v. Watkins, [1904] 1 Ch. 242. On the other hand and in contrast, where the sole duty of the agent with respect to the money is to pay it to his principal, the relationship between the parties is that of debtor and creditor: Friend v. ... Included in the amounts in respect of which late remittance penalties and interest were assessed was $9,214.17 (Andrew Paving & Engineering Ltd) and $8,853.04 (Meld Development Ltd). ...

Luigi Tiengo Art & Design Inc. v. Minister of National Revenue, [1992] 1 CTC 2097, 91 DTC 1216 Lamarre Proulx, T.C.C.J. ...

Pratt & Whitney Canada Inc. v. R., [1997] 2 CTC 2378, 97 DTC 613 Lamarre Proulx T.C.J.: This concerns a motion for disclosure of a legal opinion obtained by officers of the Minister of National Revenue (“the Minister”) on an assessment under appeal. ... This agreement is entitled: “Memorandum of Understanding between Industry, Trade and Commerce and Regional Economic Expansion and Pratt & Whitney Canada Inc.” ... Samson Indian Band & Nation v. Canada) 125 D.L.R. (4th) 294, at pages 769-73 (D.L.R. 298), to indicate that this privilege exists equally in private and public matters:... ...

Bowes & Cocks Ltd. v. MNR, 89 DTC 341, [1989] 2 CTC 2043 (TCC) Bonner, T.C.J. ... The appeals from the assessments for the 1981 & 1983 taxation years will be dismissed. ...

Gamache & Sons Logging Ltd. v. Minister of National Revenue, [1991] 1 CTC 2627, 91 DTC 824 Brulé, T.C.J. ... Harris (1904), 5 T.C. 159, the court emphasized at page 5396: ”... whether a series of transactions results in a capital gain or loss or a trading profit or loss is a question of fact to be determined after considering all of the surrounding circumstances". ...

Anjalie Enterprises Limited, C/O Teichrob Unger & Co. v. Her Majesty the Queen, [1995] 1 CTC 2802 Lamarre J.T.C.C. ... Fisher relied on Anderton & Halstead Ltd. v. Birrell, 16 T.C. 200, in which Rowlatt J. stated at pages 208 and 209, and I quote: What the statute requires, therefore, is an estimate to what extent a debt is bad, and this is for the purpose of profit and loss account. ...

Penner & Co Western LTD v. Minister of National Revenue, [1984] CTC 2017, 84 DTC 1006 Goetz, TCJ:—This is an appeal by Penner & Co Western Ltd (“the Company’’) with respect to its 1977 taxation year. ...

United Color & Chemicals Ltd. v. R., (sub nom. Vass v. R.) 98 D.T.C. 1385, [1998] 2 C.T.C. 3247 Beaubier T.C.J.: 1 These appeals for a series of tax years from 1983 to 1989 were filed in the Tax Court of Canada on November 20 and November 22, 1995 respectively. ... The present appeals will be heard on common evidence with the appeals of United Color & Chemicals Limited (95-3806(IT)G). ...

Simmonds & Sons Ltd. v. MNR, 89 DTC 707, [1990] 1 CTC 2087 (TCC) Christie, A.C.J.T.C.: —The notice of appeal and the reply thereto regarding this litigation relate to two issues. ...

Gaudreau & Associés, Avocats, S.E.N.C. v. M.N.R., docket 98-59-UI Date: 19990507 Docket: 98-59-UI BETWEEN: GAUDREAU ET ASSOCIÉS, AVOCATS, S.E.N.C., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ...