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The fact that Loblaws is primarily or mainly a retailer does not dictate a negative answer to the first question, Vide Royal Bank of Canada v D/MNR (C & E), [1981] 2 S.C.R. 139; [1982] CTC 183. ...

So it would be like trying to — A. Flow water uphill. The majority of the Board found that:... when the gas reaches the plant, it is at the same pressure as the suction of the injection compressors at 700 psi. ...

.: A reward in the form of money, books, or the like, given to the pupil who excels in attainments, usually as tested by a competitive examination”, and from Webster’s Third New International Dictionary, in which the relevant definitions are: “1: something offered or striven for in competition... as a: an honor or reward striven for in a competitive contest: something offered to be competed for or as an inducement to or a reward of effort (a school —) (The —s given at an agricultural show).“ I do not find any definition of “prize” that would apply to a reward for a merely passing a course of instruction, regardless of relative merit in it. ...

. /?., [7] Morrissey v. 7?., [8] and Landry v. R..?. [9] Some of these factors have to do with the period before the start of operations. ...

.* [3] We are of the view that the appeal should be allowed with costs in this Court and in the Trial Division, that the judgment of the Trial Division should be set aside and that the judgment of the Tax Appeal Board should be restored. 1 “What happened here was that the appellant, having found himself con strained to cease carrying on business on the premises, voluntarily destroyed the building in order to dispose of the land as advantageously as possible. 2 + A further argument was advanced based on the equitable ownership acquired by the purchaser when the agreement for sale was signed. ...

It is true that, with reference to these changes, the judgment in K v K does say, at page 778: “... ...

The rate of income tax imposed by one of the contracting States, in respect of in come (other than earned income) derived from sources therein, upon individuals residing in, or corporations organized under the laws of, the other contracting State, and not having a permanent establishment in the former State, shall not exceed fif teen per centum for each taxable year. 3 + Said Articles I and II read as follows: ARTICLE I An enterprise of one of the contracting States is not subject to taxation by the other contracting State in respect of its industrial and commercial profits except in respect of such profits allocable in accordance with the Articles of this Conven tion to its permanent establishment in the latter State. ... Subject to the provisions of this Convention such items of income shall be taxed separately or together with industrial and commercial profits in accordance with the laws of the contracting state. 4 The Queen v Richard Verrette, [1978] 2 S.C.R. 838 at 844 per Beetz, J: “In definition provisions, the word ‘includes’ is generally used extensively in contradistinction to the restrictive word ‘means’.” 5 T George Robinson v Local Board for the District of Barton-Eccles et al, 8 App Cas 798 at 801 per Earl of Selborne LC. 6 + See: A-G of Quebec v Stonehouse, [1978] 2 S.C.R. 1015 at 1025. 7 The relevant portion of subsection 248(1) reads as follows: “Property” means property of any kind whatever whether real or personal or cor poreal or incorporeal and, without restricting the generality of the foregoing, in cludes (a) a right of any kind whatever, a share or a chose in action, (b) unless a contrary intention is evident, money, and (c) a timber resource property. 8 See: United Geophysical Co of Canada v MNR, [1961] CTC 134; 61 DTC 1099; See also: Vauban Productions v The Queen, [1975] CTC 511; 75 DTC 5371; See also: Murray v Imperial Chemical Industries Ltd, [1967] 2 All ER 980 at 983; See also: The Queen v Saint John Shipbuilding and Dry Dock Co Ltd, [1979] CTC 380; 79 DTC 5297. 9 T The issue as to the applicability of Articles I and II of the Canada-US Tax Conven tion and section 6 of the Protocol and thus the franchise question, need only be con sidered if it is concluded that subject payments are caught by the charging provi sions of section 212(1). ...

They ran no risks whatsoever in conveying the property from one company to another, because they could simply have reversed the whole proceeding by another agreement, and so I must find, on my interpretation of the definition of Lord Justice Diplock (in Snook v London & West Riding Investments Ltd.) and in view of what took place in this case, that the agreement was never intended to be implemented in the manner in which it reads, but that it was always intended that Stuart would continue to operate the business and merely put money into Grover until the loss was used up and then the property could be put back where it belonged and where, I feel, it had never, in law, left. ... In effect, while he did not use the word, in the passage from his reasons for judgment quoted earlier herein, the learned Chairman of the Tax Review Board did find later in his reasons that the transaction between Stuart and Grover was a “sham” as that term was defined by Lord Justice Diplock, as he then was, in the well-known judgment in Snook v London <& West Riding Investments Ltd, [1967] 1 All ER 518. ...

(London: Stevens & Sons Ltd., 1984) at 918-19. 6 ^Kieboom v. Minister of National Revenue (1992), 92 D.T.C. 6382 (Fed. C.A.). 7 The term “amount” is thus defined in subsection 248(1) of the Income Tax Act: “amount” means money, rights or things expressed in terms of the amount of money or the value in terms of money of the right or thing, except that, (a) notwithstanding paragraph (b), in any case where subsection 112(2.1), (2,2) or (2.4), or section 187.2 or 187.3 or subsection 258(3) or (5) applies to a stock dividend, the “amount” of the stock dividend is the greater of (i) the amount by which the paid-up capital of the corpora tion that paid the dividend is increased by reason of the payment of the dividend, and (ii) the fair market value of the share or shares paid as a stock divi dend at the time of payment, (b) in any case where section 191.1 applies to a stock dividend, the “amount” of the stock dividend for the purposes of Part VI. 1 is the greater of (i) the amount by which the paid-up capital of the corpora tion that paid the dividend is increased by reason of the payment of the dividend, and (ii) the fair market value of the share or shares paid as a stock divi dend at the time of payment, and for any other purpose the amount referred to in subparagraph (i), and (c) in any other case, the “amount” of any stock dividend is the amount by which the paid-up capital of the corporation that paid the dividend is in creased by reason of the payment of the dividend; 8 % Charrier v. ...

Thus, § 7601 gives the Internal Revenue Service a broad mandate to investigate and audit "persons who may be liable” for taxes and § 7602 provides the power to "examine any books, papers, records, or other data which may be relevant... ...