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In its 1963 balance sheet, appellant Joleen Investments Limited shows among current assets an amount of $21,615.11 as “inventory — land (at cost)”. ...

While the words “... shall receive tax treatment by Canada not less favorable than that accorded under Section 99...” are quite general, I am unable to construe them in any other way, and I hold the Article does so prevent. ...

I had before be a question of the interpretation of contracts — that and only that. ...

It had two options: (a) on a full-time basis, requiring attendance Monday to Friday, inclusive, each week for one academic year September to June, inclusive, or (b) on a half-time. basis, 2 days each week for the same months for > academic years. ...

Clark, 19 T.C. 390, and Barr, Crombie & Co., Ltd. v. C.I.R., 26 T.C. 406. ...

In its context in that section the word ‘ mine” in my opinion has its ordinary meaning and this indeed was the position taken by counsel for both parties, though they differed in their submissions as to the application of the section to the facts. ...

& Cr. 359, Lord Chancellor Cottenham adopts the definition of Lord Eldon in Ex parte Pye (supra) and says, p. 367: “Lord Eldon says, it is a person ‘meaning to put himself in loco parentis; in the situation of a person described as the lawful father of the child’; but this definition must, I conceive, be considered as applicable to those parental offices and duties to which the subject in question has reference, namely, to the office and duty of the parent to make provision for the child. ...

Bieleny therefore gave to the appellant a first mortgage on the identical terms that he was to have had from the mortgage company, that is, a first mortgage in the face amount of $27,000 being the loan of $20,000 plus a premium of $7,000 at 7 % interest repayable in monthly instalments. ...

The statutory rule outlined in Section 20(6) of the Income Tax Act quoted above applies only ‘ where an amount can reasonably be regarded as being in part consideration for disposition of depreciable property of a taxpayer of a prescribed class and as being in part consideration for something else’’. ...

Hawkins & Gratton, Barristers and Solicitors, a copy of which direction is attached hereto as Schedule C. 6. ...