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& L. Inc. (”PML) was incorporated in Delaware in 1970. At all relevant times, the shares of PML were held by Arizona. ... When the partnership purchased the hotel on December 14, 1984, the purchase price of $125,500,000 was financed as follows: First mortgage to Equitable Life $ 70,000,000 Promissory notes to vendors 33,500,000 Capital from Partnership 22, 000,000 $125,500,000 The partnership as new owner had invested less than 20 per cent of the cost. ... Marsh & McLennan Ltd., [1983] C.T.C. 231, 83 D.T.C. 5180, Ensite Ltd. v. ...

Payne, “ The Dichotomy between Family Law and Family Crises on Marriage Breakdown” (1989), 20 R.G.D. 109 at pages 116-17. ... Minister of Employment and Immigration, [1985] 1 S.C.R. 177,17 D.L.R. (4th) 422,14 C.R.R. 13 at pages 206-07 (D.L.R. 459-60, C.R.R. 48-49): Like “liberty”, the phrase “ security of the person" is capable of a broad meaning. ... The intentional exclusion of property from section 7, and the substitution therefor of “ security of the person" has, in our estimation, a dual effect. ...

[Translation]; (j) The amount of $175,336.71 claimed by the appellant as so-called “ incidental expenses" [Translation] does not represent expenses which it incurred during its 1982 taxation year, but rather represents various expenses which were incurred and paid by the initial promoters of the project between June 25,1982 and December 15, 1982, the whole before the appellant became owner of an interest in the said project; (k) The amount of $175,336.71 was included in the price of $1,775,698.76 mentioned in subparagraph (f) above; (1) The so-called“ incidental expenses" [Translation] claimed by the appellant in 1982 represent the following items: Incidental expenses for the entire project (including the $937,474.20 amounts appearing in Appendix A under the first, second, x 7.57% third, fourth, fifth and sixth claim headings) $72,654.25 Interest paid to the Caisse de dépôt et de placement at the rate of 19 per cent on sums advanced prior to the appel lant’s participation: 102,682.46 lant's participation: TOTAL 175,336.71 [Translation.] 3. ... So what you do in firming up a project like that is to manage to make attitudes change so that people get closer and closer to an agreement, then say, ” Yes, we’ll do it.” ... (S.N. pages 86-87) [Translation] 4.16 On August 4, 1983, an agreement was reached between Cadev, 102077 and 1849 and the group of investors having acquired an interest in the Rockland project from Cadev, that is the appellant, La Laurentienne Mutuelle d'assurance (hereinafter called "La Laurentienne") and the Montreal Police Benevolent and Pension Society (hereinafter called the “ Police Society") (Exhibit A-5). ...

Loss from farming where chief source of income not farming. (1) Where a taxpayer's chief source of income for a taxation year is neither farming nor a combination of farming and some other source of income, for the purposes of sections 3 and 111 his loss, if any, for the year from all farming businesses carried on by him shall be deemed to be the aggregate of (a) the lesser of (i) the amount by which the aggregate of his losses for the year, determined without reference to this section and before making any deduction under section 37 or 37.1, from all farming businesses carried on by him exceeds the aggregate of his incomes for the year, so determined from all such businesses, and (ii) $2,500 plus the lesser of (A) / of the amount by which the amount determined under subparagraph (i) exceeds $2,500, and (B) $2,500 and (b) the amount, if any, by which (i) the amount that would be determined under subparagraph (a)(i) if it were read as though the words “and before making any deduction under section 37 or 37.1” were deleted, exceeds (ii) the amount determined under subparagraph (a)(i); and for the purposes of this Act the amount, if any, by which the amount determined under subparagraph (a)(i) exceeds the amount determined under subparagraph (a)(ii) is the taxpayer's “restricted farm loss” for the year. Subsection 31(1) falls under the auspices of “special cases" in Division B — Computation of Income. ... To complete the context within which the impugned provision appears in the ITA, section 11 is within Division C — Computation of Taxable Income of the legislation. ...

For a period of five years from the date hereof in the event Everett's Truck Stop Ltd. decides to sell the property and/or business at [illegible — probably Beauval], Saskatchewan, Polar Oils Ltd. shall have a right of first refusal to match any bona fide offer made to Everett's Truck Stop Ltd. on the same terms and conditions as Everett's Truck Stop Ltd. is prepared to accept from the third party, and Polar Oils Ltd. shall have a period of one month to examine an offer to purchase from a third party and accepted by Everett's Truck Stop and on or before the conclusion of the period of one month shall advise Everett's Truck Stop Ltd. of Polar Oils Ltd.'s intention to exercise its right of first refusal and purchase the property on those terms and conditions. 4. ... Had Polar paid the appellant the sum of $119,658 as the price of its committment and had the appellant paid Mel’s Truck Stop Ltd. the same amount, the use made by the appellant of the funds could not have altered the nature of the receipt in the appellant’s hands — a receipt for a commitment integrally bound up with its day-to-day business and having the quality of income. ...

Under the rule, a devise of realty to A "when" he shall attain a given age (or with any similar expression —"at" or "upon" or "from and after” but not, it seems, "if" — referring to the attainment of an age) which, standing alone, would import a contingency, will not import a contingency if the property is devised to B until A attains the age. ... & Ph. 240, 41 E.R. 482 and then only when such was accomplishable within the prescribed fiscal time constraints because the winding-up of a trust is not normally regarded as an administrative act or function qua the beneficiaries. ...

.: — The Appellant (Henry Adams) is one of 12 medical doctors whose income tax appeals were heard together on common evidence. ... For the purposes of this section, the term “Construction Advance” shall mean the advance of any moneys included in the loan budget (Schedule “B”), excluding those monies budgeted for land, the $694,050 budgeted for “Leasehold Improvements” in the space to be occupied by the Dartmouth Medical Clinic, and the $150,000 “Equity Withdrawal”. 1. … The terms in the Mercantile Bank letter (Exhibit B-5) were accepted by DMH on June 26, 1984. ...

The appellant’s income statement for 1986 indicate that its income was as follows: Development and leasing fees $ 2,297,180 Management fees 1,416,537 Share of losses of joint ventures (net of depreciation of $517,595) (167,858) Income $ 3,545,859 As of 1986, the appellant had developed ten projects. ...

The horse inventory was reflected as follows (the monetary values were provided by the appellant): As at January 1990 Item Value Value 2 mares (over 4 years old) $6,000 1 stud 5,000 2 geldings (over 4 years old) 2,000 2 yearlings 1,000 5 two-year-olds 3,000 1 pony (for family) $ 500 $17,500 In 1992 4 mares (values not itemized) 1 stud 3 aged geldings 2 yearlings 2 two-year-olds 3 foals 1 mare (for family) $20,500 As noted earlier, the plan was to have five good brood mares producing profitable sales of offspring. ... Even with lower interest rates in 1984 (10 A) and in 1985 f ^), Mr. Hoeft said he was unable to borrow to begin his feeder-cattle operation again. ...

Although Jehovah's Witnesses as a group or body have no organization as that term is ordinarily used, but are controlled and have their functions and activities directed by the directors of the Watch Tower Bible & Tract Society, and although they claim not to he a religious sect, nevertheless I think the evidence shows that they are a group which, inasmuch as they appear to have a particular system of faith or belief, might be said to come within the ordinary and general conception of the term, “religious denomination”. ... As Maclean, J. stated in Re Bien and Cooke (1944), 81 C.C.C. 316; [1944] 2 D.L.R. 137: ”... various denominations use various forms of ordination and if the procedure is satisfactory to the congregation, as appears to be in this instance, that should be considered sufficient form...”. ...