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Canadian Industrial Gas & Oil Ltd. v. Government of Saskatchewan et al., 80 DLR (3d) 449, [1978] 2 S.C.R. 545 Supreme Court of Canada Canadian Industrial Gas & Oil Ltd. v. ... The concept originated with Holmes J. in Swift & Co. v. United States [40]. It was applied in Stafford & Wallace [41] and in Chicago Board of Trade v. ...

Installation Mécanique G & B Ltée v. Minister of National Revenue, [1987] 1 CTC 2326, 87 DTC 226 Tremblay, T.C.J. ... The work to be performed was as follows: repair "the hopper — building 310 in accordance with the sketch attached hereto and Mr. ... Act — Case Law — Analysis 5.01 Act The provisions chiefly involved in this case are paragraphs 125.1 (3)(a) and (b) of the Income Tax Act and section 5200 of the Income Tax Regulations. ...

K & D Logging Ltd. v. The King, 2023 TCC 23 Docket: 2017-4536(IT)G BETWEEN: K&D LOGGING LTD., Appellant, and HIS MAJESTY THE KING, Respondent.   ... APPENDIX   Relevant Statutory Provisions:   CITATION: 2023 TCC 23 COURT FILE NO.: 2017-4536(IT)G STYLE OF CAUSE: K & D LOGGING LTD. ... Quo Vadis   Firm: Koffman Kalef For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   [1] C. ...

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. ...

In 1971 the defendant paid $75,000 to Stan Fowler Insurance Agencies Limited (hereinafter referred to as the ‘‘Fowler Agency’’) and another $53,000 to a firm of solicitors, namely, Stirling, Ryan, Goodridge, Caule, Guchus & Goodridge (hereinafter referred to as “Stirling & Ryan’’) both of St John’s Newfoundland. ... In so far as Stirling & Ryan were concerned, they had developed, in conjunction with their law practice, an insurance portfolio of some 870 insurance client files. ... On the same day, that is, May 28, 1971, a letter of acceptance of the offer was sent by Stirling & Ryan to the defendant accepting the offer of $53,000 mentioned in the letter of May 17. ...

Fraser & Beatty v. Minister of National Revenue, [1994] 1 CTC 267 Donald, J. ... Fraser & Beatty has in its possession three file folders belonging to client Y which were requested by Fraser & Beatty in order to assist Fraser & Beatty in the preparation of the representation of Mr. ... T & N pic. (1993), 77 B.C.L.R. (2d) 391, [1993] 4 W.W.R. 709 (C.A.). ...

Burns & Dutton Construction (1962) LTD v. Minister of National Revenue, [1972] CTC 2533, 72 DTC 1453 The Assistant Chairman:—This is an appeal of Burns & Dutton Construction (1962) Ltd from an income tax assessment with respect to the appellant’s 1969 taxation year. 1. Burns & Dutton Construction (1962) Ltd (hereinafter to be referred to as “Burns & Dutton”) were subcontractors for an apartment building project in Calgary and held an $89,000 contract for the installation of the footings of the building. ... Burns & Dutton was originally involved in the project as a subcontractor only. ...

Hughes & Co. Holdings Ltd., 94 DTC 6511, [1994] 2 CTC 170 Muldoon J. ... Hughes himself did not assert — was 101 hours, similarly rounded up to 105 hours. ... Dictionary of Canadian Law, Dukelow & Nuse, Carswell: FULL-TIME BASIS. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221 THURLOW, J. ... C.R. 234 at 241; [1961] C.T.C. 45 at 53. 9 + Vide Lord Macmillan in Stag Line Ltd. v. Foscolo, Mango & Co., [1982] A.C. 328 at 350. 10 [1963] S.C.R. 131; [1963] C.T.C. 51. 11 * The problem is described as follows in a note by Arnold D. ...

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. ...