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Pulp & Paper Ltd. v. The Queen, [1977] 2 S.C.R. 36 Supreme Court of Canada Price (Nfld.) Pulp & Paper Ltd. v. The Queen, [1977] 2 S.C.R. 36 Date: 1976-10-05 Price (Nfld.) ... Solicitors for the appelants: Gowling & Henderson, Ottawa. Solicitor for the respondent: D.S. ...

Supermarché Dubuc & Frère Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2215 (Informal Procedure) Garon, J.T.C.C. ... Dubuc stated that he began operating a grocery business on July 1, 1973 under the trade name Dubuc & Frères Enr. ... In the instant case the payment made by Métro-Richelieu was made to induce the taxpayer to conclude the fidelity agreement: — This payment was not associated with the purchase of property, whether equipment, rental improvements or otherwise. — This payment was not associated with expenses incurred or to be incurred by the taxpayer. — The taxpayer had absolute control over the amount received. — The taxpayer was not required to use the said amount for specific purposes. ...

Hansen & Sons Construction Ltd. (Hansen Construction) with respect to its 1979 taxation year. ... His evidence as to the appellant’s trading history can be summarized as follows: 1. 1976 — The appellant purchased the Schnell & Barrie Building. ... The acquisition of the Schnell & Barrie building had been a profitable exercise. ...

Coopers & Lybrand Limited, Agent for Mercantile Bank of Canada and Receiver and Manager of Venus Electric Limited v. ... Coopers & Lybrand Limited by virtue of the words in the floating charge debenture contract is called a receiver, but it is really an agent. ... Management only was in the care and control of the agent, the receiver, Coopers & Lybrand Limited. ...

O’reilly & Belanger, Limited v. Minister of National Revenue, [1917-27] CTC 332, [1920-1940] DTC 121 AUDETTE, J. ... & of sec. 3 of the Act which reads as follows: "" (8) In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of:— "(a) disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income. ” These provisions of the statute, like those of the English Act. do not affirmatively state what disbursements and expenses may, be deducted, and there is in words no deductions allowed at ail unless indirectly. ... This argument, he says, would require the words *‘ wholly and exclusively’’ to read "’wholly, exclusively and necessarily”: that is the very wording of the Canadian Statute. ...

Apl Oil & Gas Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2001 Margeson J.T.C.C.: — The Appellant filed an appeal from the reassessment dated August 14, 1991, number 3532072, with respect to its taxation year ending January 2, 1987. ... Attached herewith as Exhibit “B” is a copy of the August 17, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 7. ... Attached herewith as Exhibit “C” is a copy of the September 22, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 8. ...

B & D Insulation Limited v. Minister of National Revenue, [1980] CTC 2878, 80 DTC 1759 The Assistant Chairman:— By reassessment for the 1977 taxation year, the Minister of National Revenue (respondent) added to the income of B & D Insulation Limited (referred to herein as “B & D” or the “appellant”) the sum of $250,000 and, in addition to adding that amount to its income, levied penalties against the appellant pursuant to subsection 163(2) of the Income Tax Act after tax reform and section 17 of the Income Tax Act (Ontario). ... In part, this letter read: “In December, 1977, Canadian B & D had excess funds on hand and advances of $250,000 were made to each of the owner companies, these being treated as loans.” ... The interests of CANADIAN (herein Canisco) and of B & D in and to this contract, and in and to any and all property and equipment acquired in connection with this performance, together with all benefits and profits and liabilities derived from or resulting therefrom, shall be shared between CANADIAN (herein Canisco) and B & D on equal basis. ...

James McTamney & Co. Ltd. v. MNR, 89 DTC 194, [1989] 1 CTC 2318 (TCC) Christie, A.C.J.T.C.: —This appeal relates to the appellant's 1983 taxation year. ... The form of notice of forfeiture sent by mail to a pawner by the appellant reads: DEAR SIR or MADAM: — Your Loan No. of For$ is past due. ... Very truly yours, JAMES MCTAMNEY & CO. LTD. THIS LOAN COVERS Interest & Storage due. ...

Tubetest Service & Supply (1978) Limited, v. Her Majesty the Queen, [1994] 2 CTC 2320 O'Connor J.T.C.C. ... Chequing nil $ 2,375 Rec. General $ 998 $4,136 3. Only 20 per cent of the term deposits was used as security on outstanding bank loans with regard to the main business; 4. ... The company chose to reduce its taxable income to $200,000 by paying directors' and management fees and having the shareholders and management pay income taxes at high personal tax rates rather than have Tubetest Service & Supply (1978) Ltd. pay high corporate tax rates on taxable income over $200,000. ...

Granby Construction & Equipment LTD Et Al v. Vernon Robert Milley Et Al, [1974] CTC 562, [1974] DTC 6300 Bouck, J:—The plaintiffs bring this action by way of replevin for the return of certain books and records relating to each of them and alleged to be in the wrongful possession of the defendants. ... Facts—The plaintiff Granby Construction & Equipment Ltd (Granby) carried on business through 1969, 1970 and 1971 in road construction with its head office at Prince Rupert, British Columbia. ... The cheque of Manning for $36,000 was endorsed, “For deposit only to the credit of Granby Construction & Equipment Ltd. in the Royal Bank of Canada” and was negotiated on February 4, 1970 through that bank at its branch on 685 West Hastings, Vancouver to the credit of Granby’s account. ...