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FCTD

The Longueuil Meat Exporting Co Lid v. Her Majesty the Queen, [1973] CTC 386, 73 DTC 5306

On January 11, 1965 the solicitors for Longueuil Meat wrote the following letter to City Renderers Limited: Dear Sirs:— We are acting for Longueuil Meat Exporting Company Limited, and we have today been instructed by its First Vice-President, Mr David Granofsky, to write to you with respect to the following:— Our clients are seriously considering the purchase of either the fixed assets of your Company, excluding building and land, or the purchase of all the issued and outstanding Common Shares, and Preferred if any, either one at a price which we think would be attractive to you. ...
FCTD

Gourdji R Masri v. Minister of National Revenue, [1973] CTC 448, 73 DTC 5367

Following the same pattern, the four partners acquired additional property in the City of Montreal and suburbs as follows: (a) On October 25, 1955, Lots 105 and 106 in Pointe Claire for a purchase price of $356,000, payable one-half in cash, and the balance payable in five equal annual instalments, interest at 5%. ...
FCTD

Bardot Realty Limited and Joleen Investments Limited v. Minister of National Revenue, [1972] CTC 98, 72 DTC 6079

In its 1963 balance sheet, appellant Joleen Investments Limited shows among current assets an amount of $21,615.11 as “inventory land (at cost)”. ...
FCTD

Bessemer Trust Company and Ogden Phipps as Trustee (1957 Trust) v. Minister of National Revenue, [1972] CTC 473, 72 DTC 6404

While the words “... shall receive tax treatment by Canada not less favorable than that accorded under Section 99...” are quite general, I am unable to construe them in any other way, and I hold the Article does so prevent. ...
EC decision

Hart J. Levin v. Minister of National Revenue, [1971] CTC 66, 71 DTC 5047

It had two options: (a) on a full-time basis, requiring attendance Monday to Friday, inclusive, each week for one academic year September to June, inclusive, or (b) on a half-time. basis, 2 days each week for the same months for > academic years. ...
EC decision

Edgerton Fuels Limited v. Minister of National Revenue, [1970] CTC 202, 70 DTC 6158

Clark, 19 T.C. 390, and Barr, Crombie & Co., Ltd. v. C.I.R., 26 T.C. 406. ...
EC decision

The Maclean Mining Company Limited v. Minister of National Revenue, [1969] CTC 257, 69 DTC 5185

In its context in that section the word mine” in my opinion has its ordinary meaning and this indeed was the position taken by counsel for both parties, though they differed in their submissions as to the application of the section to the facts. ...
BCSC decision

Estate of Andrew Lawrence Carper v. Minister of Finance of British Columbia,, [1969] CTC 388

& Cr. 359, Lord Chancellor Cottenham adopts the definition of Lord Eldon in Ex parte Pye (supra) and says, p. 367: “Lord Eldon says, it is a person ‘meaning to put himself in loco parentis; in the situation of a person described as the lawful father of the child’; but this definition must, I conceive, be considered as applicable to those parental offices and duties to which the subject in question has reference, namely, to the office and duty of the parent to make provision for the child. ...
EC decision

Andrew Babiy v. Minister of National Revenue, [1969] CTC 693, 70 DTC 6013

Bieleny therefore gave to the appellant a first mortgage on the identical terms that he was to have had from the mortgage company, that is, a first mortgage in the face amount of $27,000 being the loan of $20,000 plus a premium of $7,000 at 7 % interest repayable in monthly instalments. ...

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