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& Sons Co. Ltd., [1969] CTC 655 JUDSON, J. (concurred in by Fauteux, Abbott, Martland and Ritchie, JJ.) ... :—Respondent by its petition of right seeks to recover the sum of $451,735.48 paid by way of sales tax upon the sale of a hot mill pursuant to a written agreement dated April 15, 1963 with a party therein described as ‘‘ Atlas Steels Company, a division of Rio Algom Mines Ltd.’’ and hereinafter called ‘‘ Atlas’’. ... In the agreement with Atlas, under the heading ‘ Price Adjustment”, the following was stipulated in clause 18: The price for the Mill shall be subject to the following adjustments: (a) the amount of any Federal or Provincial Sales Tax imposed by law;.... ...

I now turn to the relevant provisions of the Income Tax Act — subsection 9(1) and paragraph 12(1)(b). ... Premiums earned: Stevenson & Hunt accounted for these on a written as opposed to an earned basis. ... Further, Stevenson & Hunt's fiscal year was not the same as that of the insurance companies. ...

Van Lathing & Holding Co. v. R., [1996] 2 CTC 2008, [1997] DTC 129 Mogan J.T.C.C.: — In November 1987, the Appellant agreed to sell to Pan West Financial Inc. for $750,000 a 13-acre portion of Lot 7 (a parcel of land which will be described in greater detail below) in Langley, B.C. ... That was when — when I found out that they were going to go through with the sale of the land. ... That’s probably, you know, because he used the — personally I- then later on Mr. ...

Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC) Couture, C.J.T.C. ... An agreement between C.A.C., referred to as the lessor, and Fortin & Moreau Inc. ... At the foot of the first page are the words: [Translation] “Part 3 — Lease (lessee's copy)". ...

Marsh & McLennan Limited v. Minister of National Revenue, [1979] CTC 2388, 79 DTC 314 Roland St-Onge:—The appeals of Marsh & McLennan Limited and Harry Price Hilborn Insurance Ltd came before me on February 14, 1979, at the City of Toronto, Ontario and it was agreed between counsel that the evidence in the appeal of Marsh & McLennan Limited would serve for the appeal of Harry Price Hilborn Insurance Ltd (78-876). Marsh & McLennan Limited is a corporation which is incorporated under the laws of Canada, having its head office at 7 King Street East, Toronto, Ontario. ... (Northend v White & Leonard and Corbin Greener, [1975] 2 All ER 481 at 488-89). ...

Stewart & Morrison Ltd. v. Minister of National Revenue, 72 DTC 6049, [1972] CTC 73, [1974] S.C.R. 477 Judson, J (all concur):—The issue in this appeal is whether the appellant taxpayer, Stewart & Morrison Limited, in computing its income for the fiscal period ending June 30, 1966, is entitled to deduct as an expense an amount of $72,345. ... The money was lost and the losses were capital losses to Stewart & Morrison Limited. ... The case of L Berman & Co Ltd v MNR, [1961] CTC 237, relied upon by the appellant in this case, is, in my opinion, not in point. ...

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 176 Richard J.: Nature of the Proceedings 1 The moving party, the respondent Minister of National Revenue, seeks an order striking out the originating notice of motion and dismissing the within proceeding for want of jurisdiction, lack of standing, prematurity and abuse of the process of this Court. 2 In the alternative the respondent seeks an order pursuant to Rule 1614 of the Federal Court Rules (the “Rules”) extending the time limits prescribed in section Part V.1 of the Rules to allow, if necessary, an additional fourteen (14) days from the date of disposition of this motion in which to deliver the respondent's affidavit(s) pursuant to Rule 1603(3) together with leave to raise jurisdictional issues on the return of the application for judicial review. 3 In support of the motion to strike, the moving party relied on the court record consisting of the applicant's (respondent on this motion to strike) originating notice of motion filed November 6, 1997, and the supporting affidavit of Larry Bowen, the Vice President of Leaf and Product Development at Rothmans, Benson & Hedges Inc. ... Canada (Minister of National Health & Welfare), reported in(1994), [1995] 1 F.C. 588 (Fed. ...

Fleming & Co. (Machinery), Ltd. (1951), 33 T.C. 57 (Ct. of Sess.). 0997_5941_6143 3 See e.g., The Glenboig Union Five Clay Co., Ltd. v. Commissioners of Inland Revenue (1922), 12 T.C. 427 (H. of L.) at 39-40; Barr, Crombie & Co., Ltd. v. ... See Barr, Crombie & Co., Ltd. v. C.I.R., [1945] S.C. 271; 26 T.C. 406 at 411 (Scot.), Fleming, supra, at page 63. ...

Rothmans, Benson & Hedges Inc. v. Minister of National Revenue, [1998] 2 C.T.C. 408 Teitelbaum J.: 1 On February 12, 1998, Rothmans, Benson & Hedges Inc. ... Justice Richard from the case of Rothmans, Benson & Hedges Inc. v. ...

James Richardson & Sons Limited v. Minister of National Revenue, [1982] CTC 248, 82 DTC 6211 Le Dain, J:—The section 28 application must be dismissed for lack of jurisdiction on the ground that a requirement for information or documents issued under subsection 231(3) of the Income Tax Act, SC 1970-71-72, c 63. is not a decision required by law to be made on a judicial or quasi-judicial basis within the meaning of section 28 of the Federal Court Act, RSC 1970, c 10 (2nd Supp). Cf MNR v Coopers & Lybrand, [1979] 1 SCR; [1978] CTC 829; 78 DTC 6528. ...