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There are numerous phrases and guidelines used in the determination of whether an expense is capital or income in nature. [1] The key ingredient in the determination, derived from all the cases is, as was said by Lord Pearce in the B.P.Australia case, ”.. a commonsense appreciation of all the guiding features... ...

.: — This is an appeal from a judgment of Rowe D.J.T.C.C. which allowed the respondent’s appeal and vacated an assess- ment dated February 18, 1992 in which the Minister assessed the respondent pursuant to subsections 159(2) and (3) of the Income Tax Act [1] in respect of the tax liability of 323466 B.C. ...

Sparkes (1926), 70 The Solicitors Journal & Weekly Reporter 1069, where the issue to be decided was whether the addition of quinine to wine makes the mixture cease to be a wine within the meaning of the Licensing Act. ...

., for the Board said the following at page 412 (D.T.C. 526): The accepted principle appears to be that a taxing Act must be construed against either the Crown or the person sought to be charged, with perfect strictness — so far as the intention of Parliament is discoverable. ...

The Queen, [1984] C.T.C. 280; 84 D.T.C. 6283, ”... if a trader receives from another person compensation because this failure to receive another sum of money which, had it been received, would have been credited to profits, then the compensation should be regarded as income. ...

Sub-paragraph (ii) refers to the distribution of gas in portable containers — a process radically different from the restricted meaning the Plaintiff wishes to give to the word "distribute". ...

The fact that Loblaws is primarily or mainly a retailer does not dictate a negative answer to the first question, Vide Royal Bank of Canada v D/MNR (C & E), [1981] 2 S.C.R. 139; [1982] CTC 183. ...

So it would be like trying to — A. Flow water uphill. The majority of the Board found that:... when the gas reaches the plant, it is at the same pressure as the suction of the injection compressors at 700 psi. ...

.: A reward in the form of money, books, or the like, given to the pupil who excels in attainments, usually as tested by a competitive examination”, and from Webster’s Third New International Dictionary, in which the relevant definitions are: “1: something offered or striven for in competition... as a: an honor or reward striven for in a competitive contest: something offered to be competed for or as an inducement to or a reward of effort (a school —) (The —s given at an agricultural show).“ I do not find any definition of “prize” that would apply to a reward for a merely passing a course of instruction, regardless of relative merit in it. ...

. /?., [7] Morrissey v. 7?., [8] and Landry v. R..?. [9] Some of these factors have to do with the period before the start of operations. ...