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(pages 206 & 207) Subparagraph 53(1)(a)(i) of the Personal Property Security Act of Ontario provides that registration of the financing statement under the Act constitutes notice to all persons claiming any interest in the collateral and is set out below: 53.—(1) Where the collateral is other than instruments, securities, letters of credit, advices of credit or negotiable documents of title, registration under this Act, (a) a financing statement constitutes, (i) notice of the security interest to which it relates to all persons claiming any interest in such collateral, and (ii) subject to section 21, perfection of the security interest, during the period of three years following such registration. ...

It does not require the converse—that other amounts not falling within the meaning of ” receivable" be excluded from income. ...

The Queen, [1984] C.T.C. 294 at 318; 84 D.T.C. 6305 at 6325: ”... a sham transaction as applied in Canadian tax cases is one that does not have the legal consequences that it purports on its face to have. ...

Phillips put it in his argument “Seven [1] for — Twelve [2] against” his position. ...

The transfer of the shares of Mount Royal Paving & Supplies Limited to the trustee was, in my opinion, a colourable gift and not a bona fide disposition of the type which s.5(1) is intended to exempt. ...

Thereafter interest would be an even $5,000 per annum at 10% [1] *. The amount of $7,207.98 written off in 1968 had been set up as an asset and income tax paid on same in 1967 as it was not until 1968 that it was considered to be a bad debt. ...

In cross-examination, he said that to him this site represented “... a possible opportunity for a modest-sized site”. ...

In Sutton Lumber & Trading Co, Ltd v MNR, [1953] 2 S.C.R. 77; [1953] CTC 237; 53 DTC 1158 Locke, J said at page 83 [244, 1161]: The question to be decided is not as to what business or trade the company might have carried on under its memorandum, but rather what was in truth the business it did engage in.... ...

The only case which I have been able to find in which this section was discussed at all was in the Tax Appeal Board judgment in the case of Renown Steel & Services Limited v MNR, [1969] Tax ABC 678, which held that since subsection 39(6) is an exempting provision it must be strictly construed and as on the facts of the case the controller held the shares as a guarantor and not as a maker of a loan, he did not come within the provisions of subparagraph 39(6)(b)(i) so that the companies were held to be associated. ...

N 0 witnesses were called by either party and no explanation was given as to the discrepancy of $13,350 between the amount of the accounts ■ collected by Mrs. ...