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In her income tax return for the 1985 taxation year the taxpayer claimed as a deduction in computing her taxable income a " non-capital loss of other years utilized in 1985" in an amount of $84,774, the effect of which was to reduce her federal tax payable to zero. ... Recognizing that the result contended for by the taxpayer is ” unusual” the learned trial judge nonetheless felt that it was proper because of the application of section 114. ... As the trial judge rightly pointed out a deduction under subsection 20(12) is relevant to the computation of ” income". ...

HI — PART XIII — 1. All the following: (a) machinery and apparatus sold to or imported by manufacturers or producers for use by them directly in (i) the manufacture or production of goods The Issue In essence, then, the only issue is whether the pipelines are used directly in the production of saleable components of natural gas liquid which components, it was agreed, are propane, iso-butane, normal butane and pentanes plus. ...

He referred the matter back to the Minister for reassessment “on the basis that the adjusted cost base (V-day value) of 'proceeds of disposition — contract settlement' is $830,000 rather than $280,425. ... It is, therefore, excluded by the definition, supra, — test number 6. ... (dissenting): — During its 1977 taxation year, the respondent received a sum of $830,000 from Naden Harbour Timber Ltd. in circumstances that are fully recounted in the reasons for judgment of my brother Urie. ...

., with whom Hudson, J. concurred, referred to three cases which did not turn on the language of the statutes there under consideration, and said: — However, as to the other two contentions, there are three decisions that may usefully be referred to. The first of these is Robert Addie & Sons' Colleries Ltd. v. ... The shares would have been worthless, well, half of that value would have been what we received — Q. ...

Macdonald proposed to introduce a cigarette called “More” and Benson & Hedges a cigareiie called “Plus”. ... Both Macdonald and Benson & Hedges approached the Department separately, without notice to each other or the other members of the industry. ... Some time around the end of June or the beginning of July, officials in the Department agreed to adopt the view urged by Macdonald and Benson & Hedges, and these companies were so advised. ...

The Interpretation of Section 60 of the Income Tax Act The appellant submits that the rationale for the exception provided by paragraph 60(b) which, in effect, allows income splitting between former spouses or separated persons, is to distribute the tax burden between them, thus allowing them greater financial resources than when living together which, in turn, provides partial compensation for the lost economics of maintaining a single household. [3] The appellant then proceeds to quote section 11 of the Interpretation Act which deems every enactment to be remedial and requires ”... a fair, large and liberal construction and interpretation as best ensures the attainment of its objects.” ... Applying that approach to the paragraph in question, I conclude that the words employed by Parliament in paragraph 60(b) must be interpreted ”... in their ordinary grammatical sense. ... The Queen, [1977] C.T.C. 358; 77 D.T.C. 5219 per Mahoney, J. 6 It should be remembered that subsection 9(1) of the Federal Court Act and subsection 8(1) of the Tax Court of Canada both require that the Judges of those respective Courts must, before entering upon the duties of that office ”... take an oath that he will duly and faithfully, and to the best of his skill and knowledge, execute the powers and trusts reposed in him as a judge...” of the Court to which he has been appointed. ...

Reichmann & Son Limited and Webb & Knapp (Canada) Limited in connection with the acquisition of Flemingdon Park. ON MOTION duly made, seconded and unanimously carried, it was RESOLVED — 1. ...

As stated in Lindley &. Banks on Partnership (17th ed., 1995), at p. 73: In determining the existence of a partnership... regard must be paid to the true contract and intention of the parties as appearing from the whole facts of the case. ... Bromberg, Professor of Law at Southern Methodist University and counsel to the firm of Jenkins & Gilchrist. ... I think the words at paragraph 2.05 of the 17th edition of Lindley & Banks must be read in this context. ...

Only in the $0 — $10,000 and $10- $20,000 ranges are the number of winners (90 and 279 respectively) greater than the number of losers (0 and 62). ... These are the figures: Income range Winners Winners Losers $20 — $30,000 42 105 $30- $40,000 2 71 $40 — $50,000 6 18 $50,000 + — 7 Overall, in 59 per cent of the cases the parents pay less tax on the maintenance payments than they would if there was no inclusion/deduction requirement ("winners"); 37 per cent of parents suffer a tax disadvantage under the present regime ("losers") and in four per cent of cases the result is neutral. ... Assuming, for argument's sake only, that this is a legitimate exercise, the results are not very much more favourable to the government's case: Income range Wi nners Losers $0-$10,000 90 $10-$20,000 305 38 $20 — $30,000 66 82 $30- $40,000 6 65 $40- $50,000 8 16 $50,000 + 1 6 Again the winners outnumber the losers only where the income of the custodial parent is in the two lowest ranges. ...

Each partnership borrowed the following capital amounts from the First National Bank of Chicago (‘FNBC’) to finance their real estate ventures: (a) PA- US $ 48,512,600; (b) JHA- US $2,387,400; and (c) CTA- US $ 3,200,000. ... In reaching this conclusion, the Tax Court Judge made the following findings: … I do not think that the fact that the appellant paid Society Hill’s obligation under the March 1, 983 agreement constituted a fulfilment of the appellant’s obligation under its guarantee to the Bank. ... T.D.), at 6221. 5 > Cadillac Fairview, supra note I at 409. 6 McHale v. ...