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Black & Decker Manufacturing Co., [1975] 1 S.C.R. 411, 43 D.L.R. (3d) 393). ...

Nor is there any such evidence respecting his accountants Ernst & Young. ...

The following amounts were paid by him: Mortgage $2,148.00 Taxes 655.99 Water & sewer 151.50 Cablevision 59.40 Total $3,014.89 The respondent claimed as a deduction in the computation of his taxable income for the 1975 taxation year the sum of $1,256.20, which is 10/12 of 1/2 of the above total, the decree nisi having been granted in March 1975. ...

This is confirmed by Exhibit R-l which is a detailed letter from Revenue Canada in Toronto to Richter & Partners, the receiver, dated May 6, 1983. ...

The term ‘‘uncertified progress claims” as used herein, means progress claims for which architect’s certificates have not yet issued. 2 *lt seems clear from the Co/ford judgment that “holdback” as used therein is used in the wider sense and includes “uncertified progress claims”. 3 TSaid paragraph 85B(1)(b) as it applied to the taxation year 1953 reads as follows: 85B. (1) In computing the income of a taxpayer for a taxation year, (b) every amount receivable in respect of property sold or services rendered in the course of the business in the year shall be included notwithstanding that the amount is not receivable until a subsequent year unless the method adopted by the taxpayer for computing income from the business and accepted for the purpose of this Part does not require him to include any amount receiv able in computing his income for a taxation year unless it has been received in the year; Note: The said paragraph applies also to the taxation year herein under review, ie, — 1968. 4 *l use the phrase “at law having regard to the Co/ford decision. ...

In the event that any partner ("withdrawing partner") wishes to withdraw from the partnership or reduce his partnership interest and concurrently therewith a person ("new partner") wishes to become a member of the partnership to the extent of the reduction amount (as defined below) the withdrawing partner may give to the partnership 30 days' notice in writing ("notice") (which may be waived by all the partners) stipulating the amount by which the withdrawing partner wishes to reduce his partnership interest which amount may be the whole of his partnership Interest (” reduction amount”) and stipulating the identity of the proposed new partner. ...

However, the most important letter in substantive terms was that of March 1, 1984, from Mr W G Clarke, Regional Chief, Tax Interpretations — Excise to Foster Business Services Ltd, which was acting for the applicant. ...

In making that computation, the appellant included, pursuant to subparagraph 89(1)(l)(ii) of the Act,* [1] a sum of $1,350,555 in respect of the disposition that it had made, on December 23, 1976, of certain shares of Richards, Melling & Co. ...

The respondent should, in my view, be entitled to its costs in the Trial Division but should pay the appellant’s cost of the appeal. 1 See paragraphs 11 (1)(a) and 20(5)(e) and Regulation 1100(8). 2 + Subsection 84A(3) sets forth a special rule applicable to railway companies. ...

In my view, Judge Taylor erred and Judge Teskey was correct — the subsidy in this case is a taxable allowance under paragraph 6(1)(b) of the Act. ...