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.: — This appeal from a judgment of the Tax Court of Canada arises out of an assessment of the appellant’s income for the taxation year 1990, which included a portion of the cost of an expense-paid trip taken by the appellant and his wife to New Orleans on the basis that the appellant received in that year a taxable “benefit” under paragraph 6(1)(a) of the Income Tax Act, R.S.C. 1985 (5th Supplement), c. 1, as amended. ... Having said that, I note that the courts are having increasing recourse to such Bulletins and they appear quite willing to see an ambiguity in the statute — as a reason for using them — when the interpretation given in a Bulletin squarely contradicts the interpretation suggested by the Department in a given case or allows the interpretation put forward by the taxpayer. ...

The most practicable kind of legal definition would appear to be that actually used in subparagraph (D) of (ii), a well that “... will not come into production in commercial quantities wtihin twelve months of its completion.” ... Per: A R McPhee (signed) APPENDIX I DOME CZAR ET AL WEALD 6-11-5221 W5M Services Included in Turnkey Price and to be provided by Contractor Rig and Camp and Move Drilling — footage Drilling — daywork Mud and Chemicals Water Equipment Rentals Coring Testing D S T Logging Surface Casing Cementing Abandonment Service or Production Casing Cementing Camp and Crew Travel My interpretation of this contract is that the payment of $460,000 was for the materials, supplies and services provided for in Appendix I which was thought to be a relatively certain amount, and for other services, materials, equipment and supplies, which was thought to be a somewhat uncertain amount. ...

Canadian Reynolds Metals Company Limited — Société Canadienne de [Indexed as: Canadian Reynolds Metals Co. v. ... Maden & Ireland Ltd., 38 T.C. 391, [1959] 3 All E.R. 356; Tank Truck Transport Ltd. v. ... These include cryolite (NA,AIF,), aluminium fluoride (AIF sodium carbonate (soda ash — NA,CO,) and calcium fluoride (fluorspar — CAF,). ...

The tax carries the title of “ Natural Gas and Gas Liquids Tax". ... A-618-89 / A-620-89 for the cases of the first appellant and A-619-89 / A-621-89 and for those of the second appellants), on appeal from judgments of the Federal Court-Trial Division, reported [1990] 1 C.T.C. 84. ... There can be no doubt that the use of the word “ shall” is normally imperative [1]. ...

R. [1] ’, decided after the trial judgment in the present case. The provision in question in that case, subsection 55(2) of the Income Tax Act, required for its application that “one of the purposes” be to support a significant reduction in capital gain realized. ...

.: — The appeal raises two questions. 1. Were the amounts provided by the Government of Alberta to the respondent “assistance” as a grant, subsidy, forgiveable loan, deduction from tax, investment allowance or as any other form of assistance.... within the language of both subparagraph 12(l)(x)(iv) of the Income Tax Act, defining income, and of subsections 127(11.1) and 127(9) defining investment tax credits? ...

Counsel added that this interpretation was supported by the text services, or classes, grades or qualities thereof, the amount that may be deducted under this section is an amount equal to the lesser... (4) For the purposes of this section, (a) ‘allocation in proportion to patronage' for a taxation year means an amount credited by a taxpayer to a customer of that year... computed at a rate in relation to the quantity, quality or value of the goods or products... sold... to the customer... with appropriate differences in the rate for different classes, grades or qualities thereof... ” of the definition of the phrase “allocation in proportion to patronage” found in paragraph 135(4) which expressly specifies that, in the computation of the allocation, there may be "appropriate differences in the rate for different classes, grades or qualities thereof". ...

Wampole & Co., [1931] S.C.R. 494, [1931] 3 D.L.R. 754 at pages 496-97 (D.L.R. 754-55), the trial judge concluded, on the second issue, that the distribution of the directories by the appellant to its subscribers did amount, in the circumstances of this case, to a "use" of those goods within the meaning of subparagraph 27(1)(a)(iii). ...

Thill & Associates, which had in turn also received the necessary funds from Applied Research. ...

.: — The sole issue in this case is whether the respondent during its 1976 and 1977 taxation years manufactured or processed goods for sale or lease within the meaning of paragraph 125.1 (3)(a) of the Income Tax Act ("the Act") to entitle it to deduct from tax otherwise payable by it the manufacturing and processing tax credit provided by section 125.1 of the Act. ...