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After noting that paragraph 41 of IT-145R, dated June 19, 1981, was contrary to the taxpayer's position, Desjardin J. noted (p. 9): "... ...

., doubted that a judge would ever be in a position to direct the issuance of a notice of assessment because "to issue mandamus the Court must be satisfied that all the conditions have been met for the exercise of the power, and that in the circumstances the official in question has no discretionary power to delay or to refuse taking the step which is sought to be ordered by mandamus ". ...

The Queen, 2001 DTC 6681 (FCA)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence treatment not governed by accounting description Before finding that the taxpayer, in effect, had deducted reserves under s. 20(1)(m) with respect to initiation fees which, for accounting purposes, it had brought into income over the ten years following receipt on a straight-line basis, McDonald J.A. stated (at p. 6683): "... ...

" the taxpayer to whom reference is made in s. 1204(1)(b), rather than referring to "... the oil and gas business, the production of it... ...

Pipelines that distributed liquid hydrocarbons mix to a fractionation plant accordingly were "machinery and apparatus" that were used by it " directly in the manufacture or production of goods". ...

The Queen, 2013 DTC 1230 [at at 1260], 2013 TCC 292 (Informal Procedure)-- summary under Paragraph 118(1)(b) Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) "any time in the year" ≠ "throughout the year" The taxpayer appealed the denial of Canada child tax benefits and child tax credits. ...

See summaries under s. 118.1 – total charitable gifts and s. 104(1). ...

Canada, 95 DTC 5551, [1995] 3 S.C.R. 103-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning common usage of a technical term given weight After concluding that property held as an adventure in the nature of trade qualified as "inventory", and after noting that such property would qualify as inventory for accounting purposes, Major J. stated (at p. 5557): "... the Court should be cautious to adopt an interpretation which is clearly inconsistent with the commonly accepted usage of a technical term particularly where an interpretation consistent with common usage is more natural on a plain reading of the definition. ...

In finding the taxpayer liable for the penalty, Dussault J. stated (pp. 509-510): "... ...

The Queen, 2015 TCC 150-- summary under Subsection 171(1) Summary Under Tax Topics- Income Tax Act- Section 171- Subsection 171(1) reserve could be claimed on appeal Respecting an argument that the taxpayer was required by s. 20(1)(l) or (p) to have "included" the interest in income before being entitled to the reserve – whereas, in fact, neither income nor deduction appeared in the return (although an explanatory letter was attached)- Owen J stated "in any event…it is well established that it is open to a taxpayer to amend his return through the appeal process [citing Imperial Oil, 2003 FCA 289, at para. 10]" (para. 91). ...