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The first is London & Thames Haven Oil Wharves Ltd. v. Attwooll (Inspector of Taxes)', [1] decided by the English Court of Appeal. ... The first case invoked by the Minister and Tax Court Judge is London & Thames Haven. ... As stated in London & Thames Haven, an asset’s profitability is an element to be considered in assessing its capital value. ...

(e) The offices of Coopers & Lybrand, Chartered Accountants, and all storage facilities occupied or controlled by them at 201 Shepherd Street East, Windsor, Ontario. ... The applicants, Coopers & Lybrand are a firm of chartered accountants. ... The authorization to search and seize in so far as it relates to the issue in this case authorized a number of named persons to enter and search and was as follows: (d) The offices of Coopers & Lybrand, Chartered Accountants, and all storage facilities occupied or controlled by them at 500 Ouellette Avenue, Windsor, Ontario. ...

If that had been the case, there would have existed the necessary “mutuality” so that Her Majesty would have had the right of set-off claimed [6] $ and this appeal would have to be dismissed. ... Rapid Data Systems & Equipment Limited (hereinafter referred to as “Rapid Data’’) is “in the business of manufacturing electronic calculators’’. b. ... If they are remitted to someone other than the owner, the owner has no right to them. 10 t Compare N W Robbie & Co Ltd v Witney Warehouse Co Ltd, [1963] 3 All ER 613. ...

Canada, [1987] 2 C.T.C. 206, 87 D.T.C. 5415; Hillsdale Golf & Country Club Inc. v. ... Minister of National Health & Welfare, (1988) 19 C.P.R. (3d) 374. ... Minister of National Health & Welfare (1988), 19 C.P.R. (3d) 374 (EC.T.D.). ...

.), 30 & 31 Victoria, c. 3 91. It shall be lawful for the Queen, by and with the advice and consent of the Senate and House of Commons, to make laws for the peace, order, and good government of Canada, in relation to all matters not coming within the classes of subjects by this Act assigned exclusively to the legislatures of the provinces; and for greater certainty, but not so as to restrict the generality of the foregoing terms of this section, it is hereby declared that (notwithstanding anything in this Act) the exclusive legislative authority of the Parliament of Canada extends to all matters coming within the classes of subjects next hereinafter enumerated; that is to say, 3. the raising of money by any mode or system of taxation. ...

.: — In spite of the very able argument of Mr. Greene, we have not been persuaded that the judgment of the Trial Division was ill-founded. ...

.: — We have not been persuaded that the learned trial judge has committed any error that would require the intervention of this Court. ...

.: — This is an appeal from a judgment of the Tax Court of Canada, dated 16 April, 1996, dismissing the appellant’s appeal from reassessments made under the Income Tax Act (the “Act”) for the taxation years ending 31 December, 1989, 1990 and 1991. ...

.: — This application has been heard at the same time as the application in court file A426/95. ...

.: — This is an appeal from a decision of the Tax Court of Canada dated December 31, 1993 which dismissed the appellant taxpayer’s appeal from a reassessment of income tax for the 1986 taxation year. ...