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London & W. Riding Invest. Ltd., [1967] 1 All E.R. 518 at pages 528-29: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd. and the defendants were a "sham", it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ... A clear exposition of the idea is found in The Principles of Income Taxation by Hannan and Farnsworth (London, 1952, Stevens & Sons Limited). ... Attorney-General (1869), 4 E & I App. 100 at page 122, and Lord Halsbury in Tennant v. ...

He was carrying on his business under the name of Ken Allen & Sons Limited and was apparently the sole shareholder save for qualifying shares. ... Other certificates were also registered against Ken Allen & Sons Limited. ... Horses were entered in the show under the name Ken Allen and Sons — owner. ...

.: — This is an appeal from the judgment of the Honourable Mr. Justice Steele, sitting in Weekly Court, dated January 12, 1987, wherein he ordered Giuseppe Vettese to attend for cross-examination on affidavits sworn in support of four search warrants issued pursuant to section 231.3 of the Income Tax Act, S.C. 1970-71-72, c. 63, as amended by S.C. 1986, c. 6 (herein the "Income Tax Act"). ...

In construing a penal section there is the unimpeachable authority of Lord Esher in Tuck & Sons v. ...

The amounts so financed during the period from August 25, 1964 to December 31, 1965 were: Mining claims $ 5,000.00 Equipment 25,814.69 Freight and express 696.15 Geophysical expenses 1,082.68 Insurance 333.10 Legal and audit 826.96 Office expenses 23.65 Repairs, gas and oil 1,571.77 Camp expenses 5,537.00 Miscellaneous expense 74.60 Groceries for camp 535.28 Travel expenses 3,504.12 $45,000.00 The purpose of all this—according to the testimony of C C Curlett— was initially, at least, to develop and carry on an operation of recovering and removing for sale crude ore with a high copper content. ...

In Staglines Ltd v Foscalo, Mango & Co, [1932] AC 328, Lord Macmillan in speaking of the rules to be followed in interpreting such conventions, stated at 350: It is important to remember that the Act of 1924 was the outcome of an international conference and that the rules in the schedule have an international currency. ...

Ex D13 is an Air Canada air fare receipted ticket for a trip Dryden to Toronto dated April 28, 1971 $ 56.00 Ex D14 is a requisition (undated) for draft, Canadian Imperial Bank of Commerce, to be paid to Gerard Gagnon. ...

In the balance sheet of the financial statements of the appellant for its financial year ending January 31, 1963 which was appended to the appellant’s income tax return for that taxation year, there is included under the heading ‘‘current assets” an item reading as follows: Fire Insurance Claims — furniture and equipment (as per verbal offer by insurers) $20,000.00 The offer by the insurer to pay the full amount of the coverage on the property here in question forthwith constitutes a waiver by the insurer of compliance with the statutory conditions precedent to payment of the loss. ...

Third point at issue The appellant was a partner in the firm of Faucher Daviault & Associés, Chartered Accountants. ...

Subsection 152(8) is quite clear and precise, “... subject to being varied or vacated on an objection or appeal to this Part...”. ...