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Derek Darling (of the firm Healy & Darling), an accountant acting for Agri-Can at the request of Mr. ... Denni Cheng, did not work for the firm Healy & Darling before October 22, 1984; [Translation.] ... McMechan & Bourgard, Tax Court Practice, Carswell, 1994, pages 900-01 (Failure to call witness). ...

The following table illustrates these purchases: Date of Purchase Date of Sale Price Property Purchase Price Sale 3080, rue Bolduc, Montréal 6-5-82 $650,000 7-12-84 $ 785,000 2665, rue Frontenac Montréal 20-3-85 $975,000 4-11-85 $1,165,000 2154, rue Dollard, Longueuil 15-4-86 $565,000 22-5-86 $ 690,000 On November 25, 1986, the appellant, with other people, purchased a 24- apartment building located on rue St-Georges in Ville Lemoyne for $802,400, which was resold on December 30, 1987 for $1,085,000. ... M.N.R., [1982] C.T.C. 2668, 82 D.T.C. 1683 (T.R.B.); Martin & Frères Ltée v. M.N.R. (1955), 13 Tax A.B.C. 158, 55 D.T.C. 363 Counsel for the respondent referred to the following cases, inter alia; Racine, Demers & Nolin v. ...

Lang, Mich- ener, Cranston, Farquharson & Wright, First Canadian Place, Toronto, Ontario, at 2:00 pm on the 4th day of January, 1977 or at such other place and time as shall be fixed by agreement of the parties (the “Closing Date”) but with effect as of the commencement of January 1, 1977 (the “Effective Date’’). ... In Furnivall v Coombes, 5 M & G 736, the effect of the proviso, if effect was to be given it at all, was of necessity to relieve the covenantors from any sort of personal obligation, a result held to be obviously inconsistent with the intention of the transaction. ... Furnivall v Coombes (1843), 5 Man & G 736, is an illustration of the former case: William v Hathaway (1877), 6 Ch D 544, is an illustration of the latter. ...

.: — The appellant appeals from assessments of income tax for the 1991, 1992 and 1993 taxation years. ... It was a 2- axis machine in which he used a software program — basically a motion control card- that he had purchased and then programmed code to meet his specific needs. ... The following month he hired a photographer — at a cost of more than $200- to take photos of the sample doors which he used in a mail-out to various kitchen cabinet companies in Edmonton. ...

The following comment on the rule appears in “ The Law of Evidence in Civil Cases ” by Sopinka and Lederman, Butterworth 1974: Although the rule is still referred to with respect to matters other than the admission of secondary evidence of documents, it is rather by way of a rationale for assigning less weight to the evidence tendered than as a reason for its exclusion. ...

The following comment on the rule appears in “ The Law of Evidence in Civil Cases ” by Sopinka and Lederman, Butterworth 1974: Although the rule is still referred to with respect to matters other than the admission of secondary evidence of documents, it is rather by way of a rationale for assigning less weight to the evidence tendered than as a reason for its exclusion. ...

& Hamilton Ltd. et al. v. M.N.R., 33 Tax A.B.C. 63 419; D.T.C. 920 (T.A.B.). ... These principles were stressed by the Lord President (Clyde) in Collins & Sons Ltd. v. ... SHAREHOLDERS & BOARD OF DIRECTORS MEETING HELD IN LONDON, ENGLAND ON FEBRUARY 28, 1982 AT 11:00 A.M. ...

.: — Redclay Holdings Limited (“Redclay”) appeals from an income tax assessment of its 1988 taxation year and determinations of losses by the Minister of National Revenue (“Minister”) in respect of its 1986 and 1987 taxation years. ... Davie & Sons Ltd. v. Minister of National Revenue, [1954] C.T.C. 124, 54 D.T.C. 1045 (Exch.); and J.D. ... Décary J.A. added, at page 48 (D.T.C. 5412): Having said that, I note that the courts are having increasing recourse to such Bulletins and they appear quite willing to see an ambiguity in the statute — as a reason for using them — when the interpretation given in a Bulletin squarely contradicts the interpretation suggested by the Department in a given case or allows the interpretation put forward by the taxpayer. ...

The Minister of National Revenue ("Minister") assessed each of Algoa Trust and 116488 Canada Inc. (” Canada") pursuant to section 160 of the Act making them jointly and severally liable with Jaans for the latter's liability under the Act to the extent of the value of the dividends each received in 1982. ... -G., [1952] A.C. 15 (H.L.) at page 53, Lord Radcliffe interpreted “ transfer” as follows: If the word “transfer” is taken in its primary sense, a person makes a transfer of property to another person if he does the act or executes the instrument which divests him of the property and at the same time vests it in that other person. ... If this is an unintended effect of that provision — and I am not sure it is — Parliament surely will consider remedying the problem. ...

.: — This appeal is from an assessment for the appellant’s 1988 taxation year. ... In Maritime Telegraph & Telephone Co. v. R., (sub nom. Maritime Telegraph Telephone Co. v. ... Taylor & Son Ltd., [1900] 1 Ch. 577 it was held that the transport within the United Kingdom of patented articles was “making use” of them within the Patent, Designs and Trade Marks Act. ...