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Inspector of Taxes) (1933-35), 19 T.C. 390, and Barr, Crombie & Co. ... The same view was expressed by Lord Normand (the Lord President) in Kelsall Parsons & Co. v. ... Short Brothers, Ltd., 12 T.C. 955; Kelsall Parsons & Co., 21 T.C. 608. ...

[Per Curiam]: — We are not satisfied that the payments by way of strike pay in this case come within the definition of "income... from a source" Within the meaning of section 3 of the Income Tax Act. ...

Her Majesty the Queen, [1993] 1 CTC 226, 93 DTC 5158 lacobucci, |.:— We are all of the view that this appeal should be dismissed for the reasons given by Mr. ...

Solicitors for the appellant: Freedman, Cohl, Murray & Osak, Toronto. ...   [1] 122 C.C.C. 375, 29 C.R. 379. [2] 122 C.C.C. 375, 29 C.R 379. [3] Ante p. 286. [4] Ante p. 294. [5] [19551 S.C.R. 646. ...

THE COURT: Well, why don’t we — instead of doing that, why not make the finding that is against you and refer the matter back for reassessment? ... It is completely — THE COURT: You were in the case where we worked that out with reference to trading the timber limit? ... It may well be acceptable to adopt a “cash basis” — ie, taking into account for each year any cash receipts and cash expenditures in the year — for one business and equally acceptable to adopt, for a very similar business, some quite sophisticated so-called ‘‘accrual basis”. ...

The judgments below having been reported, it will be sufficient for me to summarize the facts in the following fashion: (1) two United States corporations, Federal Bulk Carriers, Inc (referred to as “Federal Bulk”) and Bessemer Securities Corporation (referred to as “Bessemer”) beneficially owned the ship Federal Monarch through subsidiary companies; the ship was chartered to Imperial Oil Limited; (2) as of July 31, 1961 the appellant purchased from Federal Buik and Bessemer the shares and outstanding notes of the holding companies for the sum of $2,325,000 and then purchased the ship from the holding companies; (3) appellant insisted on guarantees from the vendors as to ithe income to be earned by the vessel during the chartered period; that protection was derived by placing part of the purchase price into an escrow corporation and setting up a mechanism whereby the purchase price could be adjusted according to the annual income earning pattern of the investment;; (4) Federal Bulk and Bessemer jointly incorporated Bessbulk Limited, the escrow corporation (referred to as “Bessbulk”), and transferred to it the sum of $1,943,550 out of the purchase price paid to them by the appellant; Bessbulk was to invest those moneys in certain income producing assets, such income io be paid to appellant in all or in part should the revenue from the vessel be less than the anticipated amount guaranteed as above; (5) according to this 1961 agreement, should the performance of the vessel be deficient to the point that the aggregate of the actual income from its operations and of the investment income received from Bessbulk be inferior to the guaranteed amount, the shortfall, defined in the agreement as net revenue decrease, became a debt owing by Bessbulk to the appellant, to remain in existence until actual payment or until compensated by the profit derived from the future operations of the ship; (6) by agreement dated June 20, 1963 the 1961 agreement was restructured; the appellant was now agreeing to purchase from Federal Bulk and Bessemer all the outstanding shares and debentures of Bessbulk at a price which took into account the net revenue of the ship over the years and which was not payable until the charters were terminated or the ship was sold, whichever first occurred; (7) for every year of performance, the ship had a shortfall in performance; deficiencies in the ship’s net revenue for the relevant fiscai years were as follows: 1962 $ 206,932 1963 362,108 1964 307,255 1965 129,482 1966 195,302 $1,201,079 (8) the appellant received from Bessbulk in accordance with the 1961 indemnity agreement the sum of $36,058 in fiscal year 1963: (9) the appellant received from Bessbulk in accordance with the 1963 purchase agreement the following sums: Fiscal 1964 $ 55,826., 1965 60,834,, 1966 63,717 $180,377 (10) on November 19, 1965 (in the 1966 fiscal year) the ship was sold to Oswego Unity Corporation; (11) the appellant then paid for the shares and debentures of Bessbulk which it had acquired pursuant to the 1963 purchase agreement; the purchase price was calculated as follows: Net worth of Bessbulk Limited as at November 19, 1965 $2,178,953 Less Charter period deduction 984,644 Basic purchase price $1,194,309 (12) the charter period deduction was calculated as follows: Amount by which the actual revenue from the vessel was less than the projected revenue $1,201,079 Less Earnings of Bessbulk Ltd available for distribution to Maple Leaf and received by Maple Leaf 216,435 Unrecovered net revenue decrease which represented — the Charter period deduction $ 984,644 The amount in issue in the appeal before this court is this last mentioned figure of $984,644 less whatever amount is properly chargeable to the 1966 taxation year. ...

“Was I correct in holding that the Toronto General Trusts Corporation are a ‘person’ within the meaning of such word as used in the phrase ‘and to the amount of $1,500 in the case of all other persons’ as they appear in subsec. 22 of sec. 4 of the Assessment Act, namely:— “ ‘22. ... That Court reversed the judgment ([1934] O.W.N. 269) and held that the answer to the first question should be " ‘No’’. ... On the other hand, in subsees. 16 and 18 of sec. 4 of the same statute, the phrase ""derived by any person from His Majesty’s Imperial Treasury’’ is used to qualify officers ’ pay and pensions, salaries, etc.; and "‘income derived’’ is used in relation to the income which comes to a farmer from his farm. ...

At the commencement of its 1962 taxation year, appellant then known as Twin Bridges Sand & Gravel Ltd. was carrying on the business of mining, processing and selling sand and gravel principally in the immediate vicinity of Edmonton. ... Solicitors for the appellant: Bishop, McKenzie, Jackson, Redmond & Bentley, Edmonton. ...   [1] [1969] C.T.C. 397, 69 D.T.C. 5263. [2] [1970] S.C.R. 877, [1970] C.T.C. 264, 70 D.T.C. 6199, 11 D.L.R. (3d) 754. [3] [1966] S.C.R. 384, [1966] C.T.C. 150, 66 D.T.C. 5116, 56 D.L.R. (2d) 652. ...

., [1966] C.T.C. 330; Alpine Drywall & Decorating Limited v. M.N.R., [1966] C.T.C. 359; M. ... The appeal of Alpine Drywall & Decorating Limited was heard in Calgary in conjunction with that of another company by Cattanach, J. ... Esson & Sons Limited was heard at Moncton by Thurlow, J. The present appeal concerns the five named respondents only. ...

Trusts & Guar. Co.), [1939] 4 D.L.R. 417, [1940] A.C. 138. We think that the two points submitted by Mr. ...