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in Corporate Management Tax Conference — 1995, Real Estate Transactions: Tax Planning for the Second Half of the 1990s (Toronto: Canadian Tax Foundation, 1996) 6:1 at 6:15-16, quoted in Tonn at 6008. ...

The general principle of Wigmore v Thomas Summerson & Sons, Limited; Commissioners of Inland Revenue v Sir John Hubert Oakley, [1926] 1 KB 131, applies. ...

They did not “retire” in the common parlance sense of that word. 2 See, however, paragraph 36 of Exhibit 1 in this case. 3 + I do not know when the Minister first assessed and added into the defend ant’s income the amounts in question. ...

He relied in particular on London and Thames Haven Oil Wharves, Ltd v Attwooll, [1967] 2 All ER 124, where an amount recovered for loss of use of a jetty for 380 days during repair following a collision by a ship with it was held to have been properly assessed as income, and Raja's Commercial College v Gian Singh & Co Ltd, [1977] AC 312, where damages recovered for loss of the opportunity to earn a higher rent during a period in which tenants, who had been given notice to quit, overheld were considered to be assessable as income of the landlord. ...

The Queen is indivisible and wears the same crown in civil or criminal proceedings. [2] + There is jurisprudence to the effect that convictions in criminal proceedings constitute an estoppel in civil proceedings on the same subject-matter. ...

He observed [at page 291 (D.T.C. 6259)] that the Shorter Oxford English Dictionary defines "principal" as “the chief, main, or most important thing, part, point or element” and he commented [at page 290 (D.T.C. 6258]) that: The cases have held that the question of “ principal business” is a question of fact to be determined by an examination and comparison of all the facts concerning each of the various types of business in which the company is engaged. [4] In Sogemines, the predecessor corporation had as its object and purpose the carrying on of an investment business, it had only one part-time employee and no office or telephone listing, and it owned no mining equipment. ...

His total investment was just under $200,000. 2 + Warren thought, at the time, the three year period ran from the end of the contract term. ...

In 1982 the plaintiff received accounts for and paid legal fees as follows: Billed Paid Paid Balance Arbitration $14,241.25 $4,497.74 $ 9,743.51 Labour Relations Board Proceedings 13,896.61 80.50 13,816.15 Unrelated Matters 11,503.75 3,132.42 8,371.33 Total Amount Billed $39,641.65 $7,710.66 $31,930.99 The sum of $4497.74 was paid directly by the plaintiff's employer to the lawyer. ...

Com-Pakall had been recently incorporated to make the purchase and carry on the business; it was owned 10% by Long, 10% by Kuettner and 80% by Bopparder Maschinen- baugesellschaft Mbh — Bomag, hereafter “Bomag Germany”. ...

., a mortgage company which closed up one year later;-1970: the purchase of farm acreage on Pender Island which was sold ten years later at $1 million gross profit; —1974: the formation of Canada-West Charters involving some half-dozen C & C 36 sailboats, chartered on a weekly basis, and which he sold in 1980; —1982: the purchase of property in Whistler, B.C., bearing the name Unique Resorts, which he sold a year later; and-1984: the establishment of Fern Press, involved in Northwest Art lithographs and prints, which he sold at a loss a year later. ...