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The appellant was incorporated as a joint stock company pursuant to the laws of the Province of Ontario by letters patent dated November 2, 1951 under the name of Old Smokey Oils and Gas Limited which corporate name was subsequently changed to Largo Oils & Mines Limited and still later to Wardean Drilling Co, Limited, the name in the style of cause. ... Mr Abt testified that Scurry Rainbow Oil Limited paid the nominal rent on the leases for 1965 and billed the joint owners for their proportionate share. / There is no record of the payment of its share of that rent by the appellant in its financial statements but I would assume that it did so. ...

Ibid, same page: • Aluminum Company of Canada Ltd v City of Toronto, [1944] S.C.R. 267, Rand J, commented that the Famous Players case: “•.. settled that the business of one company can embrace the apparent or nominal business of another company where the conditions are such that it can be said that the second company is in fact the puppet of the first; when the directing mind and will of the former reaches into and through the corporate facade of the latter and becomes, itself, the manifesting agency. ...

Equally, clearly, in my view, a determination of a question made by the Trial Division on an application by the Minister of National Revenue in the circumstances envisaged by subsections (1) and (3) of section 174, may be the subject of an appeal to this Court, because by the terms of subsection (4) that determination is final and conclusive “subject to any appeal therefrom in accordance with the Federal Court Act ”. ... The opening words of paragraph 4, “The husband shall pay to the wife, in addition to the sum set out in paragraph 3 above ”:, indicate that this is so. ...

. * Notice may be given in various other ways — for example, in an economic statement by the Minister of Finance, a ministerial declaration (in Quebec), draft legislation, or even a press release. ...

., [1986] 1 C.T.C. 2262, 86 D.T.C. 1214, as well as Les Conventions entre actionnaires, Editions Wilson & Lafleur, Martel Ltée, 1985, under the authorship of Paul Martel. ...

Was the " expense" in question incurred by the taxpayer for the purpose of gaining or producing income from the business? ...

The passage reads as follows: [Tax convention liberally interpreted] 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. ...

This argument, however, puts a very narrow interpretation on the words ”.... amount... received... in recognition of his long service" in the definition of "retiring allowance” in subsection 248(1) of the Income Tax Act. ...

While statements furnished to Mr & Mrs Herman showing the record of their respective contributions to September 30, 1967, give a break-down of the actual amounts contributed, and the interest accrued to that date on these contributions, this is not up to date to the date of their retirement, and in any event there is nothing to indicate what portion of the pension payments they receive each year results from payments contributed by them, and of course interest continues to accrue on the amounts in the fund; moreover Mr Herman testified that the payments have been increased since 1972 by an escalation for cost of living. ...

.: — Relief Requested This is an appeal against a reassessment by the defendant of the plaintiff's income tax for her 1982 taxation year, in respect of the gain realized by her in the disposition of Lot 77, Section 31, Nanaimo District, Gabriola Island, Plan 23760. ...