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Block Research & Development (1981) Corp. v. MNR, 87 DTC 5137, [1987] 1 CTC 253 (FCTD)-- summary under Subsection 223(1) Summary Under Tax Topics- Income Tax Act- Section 223- Subsection 223(1) "[T]he liability to pay tax under the Income Tax Act arises before any assessment has been made" and "under the Act, the Minister is entitled to assess at any time and is not bound to wait for the end of a fiscal year. ...

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)-- summary under Public Policy Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Public Policy Fines paid by the taxpayer, a trucking company, for violations of highway weight restriction laws "resulted from the day to day operation of its transport business and were paid as a necessary expense," and accordingly were deductible. ...

Johnson & Johnson Inc. v. The Queen, 92 DTC 6373, [1992] 2 CTC 86 (FCTD)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business A federal sales tax refund was taxable income given that the receipt was linked to the taxpayer's income-earning process (the price at which the taxpayer sold its products included the federal sales tax, although the taxpayer felt it had no responsibility to pass on the amount of the refund to its customers). ...

Johnson & Johnson Inc. v. The Queen, 92 DTC 6373, [1992] 2 CTC 86 (FCTD)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement A federal sales tax refund was taxable income given that the receipt was linked to the taxpayer's income-earning process (the price at which the taxpayer sold its products included the federal sales tax, although the taxpayer felt it had no responsibility to pass on the amount of the refund to its customers). ...

Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. ...

Squibb & Sons Ltd. v. MNR, 73 DTC 5139, [1973] CTC 120 (FCTD)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose In 1952, the taxpayer purchased 52 acres of land outside Montreal in order to construct its own facilities for use in research, manufacturing and marketing. ...

Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD)-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property The taxpayer acquired machinery by having a rental company make the purchase and then entering into various leasing agreements with the rental company containing an option to purchase the equipment for $1, for 5% of a relatively minor amount otherwise owing under the lease or for the balance owing under the lease. ...

Queen & Metcalfe Carpark Ltd. v. MNR, 74 DTC 6007, [1973] CTC 810 (FCTD), aff'd [1976] CTC xvi (FCA)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) changes in character of the rented-out facilities did not matter The proposed renting out of hotel premises or a cinema structure was implicitly treated as part of the taxpayer's business of acquiring various properties and leasing them out for rental use, notwithstanding that it had never rented out facilities of this character before: "the fact that the realty handled and leased by the appellant is of a different type or kind than that contemplated by the structure [in question] makes no difference. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Accounting Principles Summary Under Tax Topics- General Concepts- Accounting Principles Before finding that both ss.20(1)(c) and 12(1)(c) "require accounting in conformity with ordinary commercial practices and/or generally accepted accounting principles" (p. 6188) Reed J. stated (p. 6186): "A distinction must be made between a requirement that income for tax purposes be accounted for generally in conformity with accounting principles and a requirement that the taxpayer's treatment of his financial statements and his tax returns be identical. ...

Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) It was stated, obiter, that s. ...