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Grandin Park Barber Shop & Beauty Parlour LTD v. Minister of National Revenue, [1984] CTC 2121, 84 DTC 1071 Sarchuk, TCJ:—Grandin Park Barber Shop & Beauty Parlour Ltd. ... Subsequently on April 26, 1978 the appellant acquired a 34 per cent undivided interest in a parcel of land in Caroline, Alberta, described as Pt NE 1/4 — 13 — 36 — 6 — W — SthM (the “Caroline property”) for a price to the appellant of $40,800. ... The Concise Oxford Dictionary defines replace at page 951: replace — “Put back in place; take place of, succeed, be substituted for; (in pass) be succeeded or have one’s or its place filled by, be superseded; fill up place of (with, by), find or provide substitute for.” and substitute at page 1151: substitute — “1. ...

COURT FILE NO.:                                                 2000-3982(EI) and 2000-3984(CPP) STYLE OF CAUSE:                                               Sara Consulting & Promotions Inc. v.                                                                                 ... Bell DATE OF JUDGMENT:                                       November 20, 2001 APPEARANCES: Counsel for the Appellant:                  Carman P. McNary Counsel for the Respondent:              Margaret McCabe COUNSEL OF RECORD: For the Appellant:                 Name:                Carman P. ...

Procon Mining & Tunnelling Ltd. v. The Queen, 2022 TCC 71, aff'd 2024 FCA 1 Docket: 2017-4641(IT)G 2019-2446(IT)G BETWEEN: PROCON MINING & TUNNELLING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... The other issuer’s press release also describes Procon’s acquisitions of its shares as an “ Investment by Procon” and similarly describes Procon having agreed to acquire the shares “ for investment purposes ”. 5) The Book of Documents includes another press release of one of the issuers indicating that, in addition to Procon acquiring its shares, Mr. ... Canada (Minister of National Revenue — M.N.R.), [1967] 1 Ex. C.R. 245 at p. 257. ...

Hi-Rise Electric & Signs Ltd. v. M.N.R., docket 98-159-CPP Date: 19990910 Dockets: 98-995-UI; 98-159-CPP BETWEEN: HI-RISE ELECTRIC & SIGNS LTD., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... ISSUE: [1] The issue is whether ten employees of the Appellant were, from March 1, 1997 to August 20, 1997 in "insurable employment" as that term is set out in section 5(1) of the Employment Insurance Act (" Act ") and whether they were in pensionable employment within the meaning of the Canada Pension Plan (" CPP "). ...

A & D Precision Limited v. The Queen, 2019 TCC 48 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Russell” Russell J.   Citation: 2019TCC48 Date: 20190228 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Introduction: [1]   This is a scientific research & experimental development (SR&ED) case. ...

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-272-CPP Date: 19990803 Docket: 1999-272-CPP BETWEEN: OIL & RUBBER SPECIALTIES INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and LOUISE RICHARD, Intervenor. ... (iii) ownership of tools – what was provided to the Worker to perform his/her work, if anything? ... The test is conclusive – all the evidence must be examined and the tests applied in order to determine the totality of the relationship at issue. ...

La Ronge Lumber & Electric LTD v. Minister of National Revenue, [1985] 2 CTC 2271, 85 DTC 573 Sarchuk, TCJ:—The appeal of La Ronge Lumber & Electric Ltd (La Ronge) relates to an assessment by the Minister of National Revenue of penalty and interest on the appellant’s income tax liability for its 1981 taxation year. ... Mr Garrison responded by letter dated November 18, 1981 in the following words: We have completed the necessary arrangement with the Bank of Montreal, La Ronge, for Guarantees as follows: Edwin Elton Tubman — $21,874.22 La Ronge Lumber & Electric Ltd. — 16,466.76 The latter amount is $7,000.00 more than required. ... It is well settled law that “... When a debtor is making a payment to his creditor he may appropriate the money as he pleases, and the creditor must apply it accordingly. ...

Oil & Rubber Specialties Inc. v. M.N.R., docket 1999-38-CPP Date: 19990803 Docket: 1999-38-CPP BETWEEN: OIL & RUBBER SPECIALTIES INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and PAUL E. ... (iii) ownership of tools – what was provided to the Worker to perform his/her work, if anything? ... The Worker was held out by the Appellant to be an integral part of Oil & Rubber Specialties Inc. on the Worker's business cards and on the Appellant's organizational charts – all of which were entered as exhibits during the trial. ...

Appeal of R & L Investments Ltd. These are the matters in dispute regarding R & L Investments Ltd. ... The allocation of the $19,008.66 to taxation years is 1981 — $6,892.08, 1982 — $6,400.37 and 1983 — $5,716.21. ... The selling broker was Murdock & Maber Agencies Ltd. and it issued a receipt for $5,800 to R & L. ...

They read: PURCHASE PRICE BREAKDOWN AGREEMENT ON THE PURCHASE OF J & L VIDEO LTD. ... The subject line is: "Re: Sale of Assets — J & L Video to Len Hryciw". ... Even in that context it does not speaK of J & L Video Ltd. acquiring anything. ...