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S & S Properties Limited v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294 at 419 [6298] where Walsh, J in quoting from Roy M Powers Her Majesty the Queen, [1975] CTC 580; 75 DTC 5388 and the judgment of Addy, J therein states: Yet, one cannot say that, as a matter of law, every land developer is precluded from establishing that in a particular case there was no primary or secondary intention to speculate anymore than in a case such as the one at Bar where a mature man has never previously resold a piece of real estate at a profit, is one precluded from finding that, on his very first venture in this sphere, he did in fact have the intention of reselling at a profit when he originally purchased the lands. ...

Michael’s carried with it an appointment to the University — Dr. Marotta became a lecturer. ...

Coopers & Lybrand Limited, supra, at page 6547, as follows: In Crown Tire, Strayer was required to construe the phrase as it is used in paragraph 125.1(3)(a) of the Act. ...

.: — This is an appeal by way of trial de novo from a decision of the Tax Court of Canada, dated April 5, 1991, which allowed the defendant’s appeal from reassessments for the taxation years 1980, 1981, 1982, 1983, 1984, and 1985. ...

The plaintiff’s assessment for the taxation year 1966 will be referred back to the Minister for reassessment not inconsistent with these Reasons. 1 See: Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] CTC 99; 70 DTC 6085, and Pigott Investments v The Queen (supra). ...

(r) Both corporations changed their taxation year to December 30 in 1971 and the sales and net income reported have been the following for each corpora- Defendant Covertite (Ontario) Ltd Year ending Dec. 30/71 Sales $ 806,843 $501,957 Net income 39,368 22,615 Year ending Dec. 30/72 Sales $1,141,655 $577,096 Net income 31,176 21,479 (s) The combined taxable incomes of the Defendant and Covertite (Ontario) Ltd. were as follows for the taxation years ending on the indicated dates: Jan. 31/71 62,315.09 Dec. 30/72 $70,907.00 From the figures given in (m) and (n), it is clear that the defendant company was consistently adjusting its salaries and bonuses so that the net profit remained just below the amount at which a higher tax rate would have been payable, which showed the importance of tax considerations in the defendant’s and Mr Warner’s activities. ...

. — File No. T-2626-85 [since reported at [1986] 1 C.T.C. 110; 86 D.T.C. 6027], where it was held that certiorari was available to the applicant, and the assessment and requirement to pay were quashed. ...

Whelan, who subsequently became president of Oil & Gas, Kaiser Petroleum Ltd., could add that as the events unfolded, no material changeover in personnel took place. ...

Justice Dubé in the case of Director of Investigation & Research: the Competition Act, R.S.C. 1970, Chap. ...

I cannot accept that evidence nor can I regard, as I was invited to do, the total amount of payment as representing compensation in lieu of damages. dent, this would produce a total amount of some $243,750 (ie, $75,000 39 + 12 $243,750. ...