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Interworld carried on business from an office in a suite of offices where Rose & Persiko, a firm of Toronto solicitors, carried on business. ...

On January 11, 1965 the solicitors for Longueuil Meat wrote the following letter to City Renderers Limited: Dear Sirs:— We are acting for Longueuil Meat Exporting Company Limited, and we have today been instructed by its First Vice-President, Mr David Granofsky, to write to you with respect to the following:— — Our clients are seriously considering the purchase of either the fixed assets of your Company, excluding building and land, or the purchase of all the issued and outstanding Common Shares, and Preferred if any, either one at a price which we think would be attractive to you. ...

Following the same pattern, the four partners acquired additional property in the City of Montreal and suburbs as follows: (a) On October 25, 1955, Lots 105 and 106 in Pointe Claire — for a purchase price of $356,000, payable one-half in cash, and the balance payable in five equal annual instalments, interest at 5%. ...

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. ...

This actual valuation was established on the basis of the valuation by three experts, one of whom, Mr Madison H Haythe, vice-president of the well-known investment firm of Morgan Stanley & Co, testified in Court. ...

I see no reason for so limiting the scope of the words in section 24, particularly the words authorizing the Minister at any time to “... assess, re-assess, or make additional assessments upon any persons... for duties, interest and penalties”. ...

The owners insisted on selling the whole of their properties, or none at all. 11 In order of date, the deeds of purchase, and the agreed sale prices, were as follows: Mary St Louis-- April 5, 1965-- $165,750 LaPorte-- May 20, 1965-- $ 35,000 James St Louis-- June 1, 1965-- $150,000 12 The transactions were ultimately paid in cash, except in respect of the James St Louis farm. ...

It is, as applied to this case, “... his income for the year from all duties performed by him in Canada...”. 14 As has been said over and over again, the statute does not define “income”. ...

DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT   ...