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A large insurance broker, Thomason & Saunders, approached Clarkson, Gordon & Co, Trustees in Bankruptcy, with respect to the purchase of the list of customers and negotiated with one Donald Gardner, CA, of the bankruptcy division of Clarkson & Gordon, who was appointed official Trustee in Bankruptcy as a result of a Proposal filed on February 4, 1975. ... There was a subsequent letter, however, written on April 22, 1975, on Hugh & McKinnon Ltd letterhead, with the knowledge and approval of Mr Davidson, whereby the people on the customer list were again contacted and requested to direct their inquiries to Mike and Brian “now located at Hugh & McKinnon Ltd, 5678 — 176th Street, Surrey, BC”. ... At 730 and 6447 respectively, Collier, J states: In my opinion, when one views the “practical and commercial aspects”* [1] of this purchase, the plaintiffs were in reality acquiring, or endeavouring to acquire, an opportunity for potential future customers or business — the trade of the clients of C F Graves & Co. ...

Eplett & Sons, Limited v. Minister of National Revenue, [1954] CTC 356, 54 DTC 1189 THORSON, P. ... Gray Member. ” On March 15, 1945, Mr. Elliott wrote to the appellant as follows: ‘ ‘ Sir: Re Excess Profits Tax Act, 1940 Standard Profits Claim. ... Elliott’ Deputy Minister (Taxation) ”’ The appellant’s claim was made under Section 5 of the Act without specific reference to any subsection of it. ...

Station Canada & Gulf Terminal Inc v. Minister of National Revenue, [1980] CTC 2805 Roland St-Onge:—L’appel de la compagnie Station Canada & Gulf Terminal Inc est venu devant moi le 22 mai 1980 dans la ville de Quebec (Quebec). ll s’agit de déterminer la valeur d’un terrain au 31 décembre 1971 afin de connaître le montant du gain en capital pour l’année d’imposition 1975. ... Représentant la firme Ménard, Marsan & Associés de Rimouski, monsieur Ménard a déterminé une valeur au jour d’évaluation, ou “V-Day” de $0.32 le pied carré. Le témoin Jacques Sauriol de la firme Leroux, Beaudry, Picard & Associés Inc, sans tenir compte des améliorations, a fixé une valeur de $0.265 le pied carré. ...

-Ni ‘ Nicholas Detoro v. Minister of National: Revenue, [1965] CTC 321, 65 DTC 5194 CATTANACH, J. ... The appellant’s case is set out in his Notice of Appeal as follows: " At no relevant time has the Appellant purchased and sold real estate for the purpose of earning income and at no time has the Appellant dealt or traded in shares of the capital. stock of corporations as a business. ... George Street Ltd., together with a further realization of the shares of such company at a profit to the Appellant of $18,440.73 is income from a business within the meaning of the word as defined in the Income Tax Act. ’ ’ The question for determination is whether the profit realized on thé sale of the shares at 151 St. ...

Fraser & Company Limited v. Minister of National Revenue, [1948] CTC 297 Lord MACMiLLAN:—In the fiscal year 1940-41 the appellant company, in pursuance of their business as lumbermen, held three Government licences under which they cut timber in three areas of Crown Land in the Province of Alberta. ... ‘ The appellant company gave notice to the Minister of their dissatisfaction with his decision and of their desire that their appeal be set down for trial. ... Elliott in cross-examination explained that his disallowance of the deduction claimed was based not only on his conception of the legal position of the appellant company in relation to their timber limits but also on the view that they had been allowed as expenses ‘‘all expenditures incurred in securing the timber ‘ ‘ and had 14 made no capital investment which we feel required depletion’’. ...

David $. Christie, Executor or the Estate or Charles S. Christie v. Minister of National Revenue, [1968] CTC 371, 68 DTC 5240 CATTANACH, J. ... Christie had in the estate of her father as remainderman subject to the life interest of her mother was an ‘‘interest in expectancy ‘ ‘ within the meaning of those words as they appear in Section 58(1) (s) (i) of the Estate Tax Act and as those words are defined in Section 58(1) (k) and that accordingly the Minister’s valuation of that interest for the purpose of assessment of Mrs. ...

Morasch Builders & Supplies LTD v. Minister of National Revenue, [1972] CTC 2386, 72 DTC 1333 Roland St-Onge:—This appeal was heard in the City of Calgary in the Province of Alberta by the Tax Review Board on March 16, 1972 and involves the 1965 and 1967 taxation years. ... In 1965 the company advertised and sold this remainder in three different parcels: 25 acres to a Mr Wathen for $11,000; 25 acres to a Mr Rurar for $24,900; and 35 acres to Kouitz & Golden for $39,000 — realizing a gain of $49,674. ... Mr Morasch had been personally buying and selling land and houses for himself as well as for others, and the transferring of the land to his company to be sold at a profit — a company, part of whose business had also been the buying and selling of properties — does not constitute a means of preventing taxation of the gains. ...

In Re Atkins & Durbrow (Erie) Ltd. Et Al., [1968] CTC 405 DOHM, J. ... Milner and the partnership Val & Co. as of August 11, 1966 held all but eight of the 1,000,000 common shares of Atkins & Durbrow (Erie) Ltd. ... The following day cheques totalling over $200,000 were issued by the company Atkins & Durbrow (Erie) Ltd. to other companies Atkins & Durbrow Ltd., Bushland Products Limited and Acadia Securities Ltd. ...

Queen & Metcalfe Carpark Ltd. v. MNR, 74 DTC 6007, [1973] CTC 810 (FCTD), aff'd [1976] CTC xvi (FCA) Sweet, D.J. ... November 6, 1967 $2,182.57 December 30, 1967 $4,164.94 December 15, 1967 $ 279.98 February 9, 1968 $2,019.32 March 11, 1968 $ 320.03 April 11, 1968 $ 79.60 May 14, 1968 $ 12.03 May 31, 1968 $ 12.35 August 31, 1968 $ 4.15 Smith, Winston, Wolman, Roth & Smith November 7, 1967 $500.00 This is a firm of chartered accountants. ... A H Fitzsimmons & Co Limited December 22, 1967 $1,025.30 March 30, 1968 $1,307.17 Mr. ...

(“Skylight”), Suresh Kumar Aravindakshan (“Suresh”) and Titus George (“Titus”) in respect of assessments issued to them, under the Employment Insurance Act (the “ EIA ”) [1] and the Canada Pension Plan (the “ CPP ”) [2], by the Minister of National Revenue (the “Minister”), as represented by the Canada Revenue Agency (the “CRA”). ... ELLEITHY: … I did notice that … a lot of the wording is very similar. ... Aravindakshan is earning 70 % agent’s commissions as agreed at the time of acceptance. ...