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S & S Properties LTD v. Minister of National Revenue, [1977] CTC 2267 Roland St-Onge (orally: March 25, 1977):—The appeal of S & S Properties Ltd came before me on March 22, 1977 at the City of Victoria, British Columbia, and the question at issue is whether a gain earned in the appellant’s 1973 taxation year is taxable or not. ...

Kelly, Douglas & Company Limited v. Minister of National Revenue, [1976] CTC 2107 A W Prociuk (orally: October 31, 1975):—The appellant, Kelly, Douglas & Company Limited, appeals from the respondent’s reassessment of its income for the taxation year ended December 31, 1971, wherein the deduction of $53,331, representing the cost of its stationery and special forms on hand at the end of the year, from its income was disallowed on the ground that it was inventory within the meaning of subsection 14(2) and paragraph 139(1)(w) of the Income Tax Act then in force, and should be carried forward into the succeeding year. ...

Bates Construction & Development Corporation v. Minister of National Revenue, [1973] CTC 2277, 73 DTC 234 The Assistant Chairman:—The appeal is from a tax assessment for the 1969 taxation year. Counsel for the parties agreed on the following facts: The fiscal period of Bates Construction & Development Corporation (hereinafter called “Bates Construction”) ends on September 30. ...

J Comtois & Fils Ltee v. Minister of National Revenue, [1978] CTC 3214, [1979] DTC 1 Guy Tremblay:—La présente cause fut entendue à Montréal (Québec) le 11 mai 1978. ... Ici, le cheque de la compagnie d’assurance n’a pas été fait à l’ordre de J Comtois & Fils mais à ses créanciers. ll s’appuie également sur l’opinion émise dans le Bulletin d’interprétation no 293, au paragraphe 19: 19. ... Il y est dit que l’acheteur Joseph Comtois & Fils Limitée a pris une assurance de “The Prudential Insurance Company of America” (police groupe G L-360) sur la vie d’une personne dont apparaît “sur la ligne B plus bas”. ...

Canadian-American Loan & Investment Corporation Limited v. Minister of National Revenue, [1972] CTC 2559, 72 DTC 1463 A J Frost:—This is an income tax appeal in respect of the appellant’s taxation year ended June 30, 1967. ... By agreement dated September 30, 1966 the appellant entered into an agreement with Georgia which reads in part as follows: IN PURSUANCE OF THE “SHORT FORM OF LEASES ACT” Between: Canadian-American Loan & Investment Corporation Limited hereinafter called the “Lessor” of the First Part: And: Georgia Marina Boat Works Limited hereinafter called the “Lessee” of the Second Part: WITNESSETH, the said Lessor doth demise unto the said Lessee, his executors, administrators and assigns, ALL AND SINGULAR that certain parcel or tract of land and premises situate, lying and being in: the; Municipality of Richmond more specifically designated as Lot A of Lot 14 Block A Section 29 B.N. 5 R.W.6 Map 51813F and in particular the frame building thereon used for the purpose of housing boats of all kinds, under rental agreements with the owners, for various periods of time. ...

L & F Holdings Ltd. v. Minister of National Revenue, [1975] C.T.C. 2192, 75 D.T.C. 150 R St-Onge (orally: April 11, 1975): 1 This appeal is from a reassessment dated October 25, 1973 in respect of the 1972 taxation year and came before me on April 9, 1975 in the City of Winnipeg, Manitoba. ... She has also borrowed from her family the following amounts, which appear on the company's December 31, 1972 financial statement: (1) from her husband, Leon Raber $65,000 (2) from her daughter, Frayda Raber (20 years old) 6,100 (3) from her son, Lionel Raber (17 years old) 4,500 7 The appellant company's activity in 1972, 1973 and 1974 reveals the following transactions: (A) Money lent on mortgage: in 1972—Nil in 1973—one of $17,000 to Mr Bryck in 1974—3 mortgages (B) In 1972 the appellant company renewed four loans on promissory notes, namely: (1) Genevieve Holdings Ltd—$70,000 12.5% (2) Jean Horban (amount of loan not specified) 12.5% (3) Patricia Horban (amount of loan not specified) 10% (4) L Miles—$27,887.42 12% Besides the renewal of these four loans, the appellant company made three new loans on promissory notes. 8 In 1972 she was the only employee of the company and received $15,000 from her husband's business and nothing from her own company, but in 1973 she received $5,600 from the appellant company, which also paid $900 to each of her two children for answering the telephone and for making some deposits at the bank. 9 Mrs Raber's work for the appellant company was to contact clients, prepare the deposits, meet with the lawyer and accountant, collect the accounts receivable and keep the books of account. 10 As to the collection of money, all the payments were made by postdated cheques and the company had some 16 clients in 1972, most of them being friends of the family. 11 One of the clients, Sabray Investment Ltd, was owned by a Mr Hirsch and a Mr Gindin who were also clients of the appellant company. 12 Two weeks after receiving a letter from the Income Tax Department, addressed to the appellant company's accountant and saying that the company's income was not from an active business, a small advertisement was published in the Winnipeg Free Press saying: “Funds available for first and second mortgages—L & F Holdings Ltd—489–8560” 13 Mrs Raber terminated her testimony by saying that the appellant company did not have any trouble collecting its money; that in 1972 she had worked an average of four hours a day for her company; that in the same year she did not have any specific time to work for her husband although she was receiving $15,000 from him and nothing from her own company; and that out of an amount of $274,000 in loans, $200,000 was borrowed from members of her family. ...

Buegeleison & Jacobson Limited v. Minister of National Revenue, [1978] CTC 2142, 78 DTC 1103 A J Frost:—This is an income tax appeal relating to a notice of reassessment dated August 27, 1975 with respect to the appellant’s 1974 taxation year. ...

Nomad Sand & Gravel LTD v. Minister of National Revenue, [1982] CTC 2035, 82 DTC 1070 The Chairman:—The appeal of Nomad Sand & Gravel Ltd is from assessments with respect to the 1974, 1975, 1976 and 1977 taxation years. ... The appellants, pursuant to Regulation 1201, also sought to deduct / of their profit from the business by claiming that gravel was a mineral resource. The Minister disallowed both the 50% capital cost depreciation and the deduction of / of the appellants’ profit under Regulation 1201. ...

R & L Food Distributors Limited v. Minister of National Revenue, [1977] CTC 2579, 77 DTC 411 A W Prociuk:—The appellant corporation of Tecumseh, Ontario appeals from the respondent’s reassessment of its income for the 1973 taxation year wherein the small business deduction pursuant to subsection 125(1) of the Income Tax Act, SC 1970-71-72, c 63, as amended, was disallowed on the ground that the appellant was not a Canadian-controlled private corporation in that the controlling shareholders were not resident in Canada. ...

J G Young & Son Limited v. Minister of National Revenue, [1972] CTC 2370, 72 DTC 1319 A J Frost:—This is an appeal from an income tax reassessment dated July 28, 1970 varying an earlier assessment dated May 14, 1969 in respect of the appellant’s 1967 taxation year, wherein the Minister of National Revenue levied an additional tax on the gain realized on the sale of 4 acres of land in the sum of $72,830.93. ...