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As Driedger points out in "The Spending Power” (1981), 7 Queens' L.]. 124, Canadian governments (of all levels) have never restricted spending to matters within their respective legislative competence — certainly not in areas in which there may be a double aspect. ... It argues that Parliament cannot directly prohibit extra-billing (over and above health care P y™ ") by doctors, so it cannot achieve the same end by the conditions attached to funding. ...

Although we think that the explanation of the case by Lord Sumner in the Egyptian Delta case [1929] AC 1; 98 LJKB 1; 140 LT 50; sub nom Todd v Egyptian Delta Land & Investment Co, Ltd, 14 TC 119: Digest Supp produces, in effect, that result, nevertheless, the passage which we have cited above from Lord Cave’s speech seems to us to show that, in his opinion, residence in England could be supported, though the “central control and management’’ was concentrated in Sweden. ... They said: *... Clearly someone has a duty to do something about this absurd and unjust situation. ...

When market conditions make it practicable and when the A and B reefs have been gone over the second time, which means that 50 % of the pillars is removed, then at that future time the D, E and F reefs will be mined simultaneously. ... Because the subsidiary was without a backlog of security the bank insisted upon a guarantee of the subsidiary’s indebtedness by the appellant, but it was Con-Ell that contracted the debt as principal and the appellant acted as guarantor only and the appel- lant also acted as guarantor of Con-Ell to Central Mortgage & Housing Corporation with which corporation Con-Ell contracted directly. ...

Therefore in 1981 when the unit was used for 71 days, 25 of which were personal and 46 of which were business, the formula application was: 46 over 71 x 100 = 64.78 per cent of expenses deductible for business or $5,865.42 out of the total expenses of $9,023.73. ... & 3. (a) Gaining or producing income from a business and (b) Personal or Living Expenses In order for the appellant to be successful under heading (a) above, he must be able to satisfy the Court on a balance of probabilities that the expenses were incurred "for the purpose of gaining or producing income from a business" within the meaning of paragraph 18(l)(a). ...

Rayner & Keeler Ltd. (No. 2) 4, at p. 935, defined the requirements of issue estoppel as:... (1) that the same question has been decided; (2) that the judicial decision which is said to create the estoppel was final; and (3) that the parties to the judicial decision or their privies were the same persons as the parties to the proceedings in which the estoppel is raised or their privies... ... It will not suffice if the question arose collaterally or incidentally in the earlier proceedings or is one which must be inferred by argument from the judgment. [...] ...

.: — Dissension reigned in 1979 among the four shareholders of Les Industries S.L.M. ... According to the Minister, S.L.M. artificially or unduly created a loss of $ 1,000,000. ...

.: — 1. Issue This case raises an important and controversial issue concerning the interpretation of ss. 67(1)(b) and 91 of the Bankruptcy and Insolvency Act, R.S.C., 1985, c. ... Ramgotra transferred the funds from his two RRSPs into his exempt RRIF when he was solvent, and not for the purpose of defeating his creditors, one might well wonder how the bank could get around the exempt status of the RRIF — a status which, on its face, constitutes an absolute bar to the bank’s claim. ...

I use the term “ significantly profitable” because it appears from the Morrissey decision that the quantum of expected profit cannot be ignored and I take this to mean that one must have regard to the relative amounts expected to be earned from farming and from other sources. Unless the amount reasonably expected to be earned from farming is substantial in relation to other sources of income then farming will at best be regarded as a “ sideline business” to which the restriction on losses will apply in accordance with subsection 31(1). ...

Collier & Sons Ltd. (hereinafter called Collier) for the early part of 1982 and the latter part of 1985, and with Grolier Ltd. ... Block Research & Development (1981) Corporation v. M.N.R., [1987] 1 C.T.C. 253, 87 D.T.C. 5137 and my own decision in the case of Gibbs v. ...

Nomad Sand & Gravel Ltd., [1991] 1 C.T.C. 60, 91 D.T.C. 5032 (F.C.A.) do not apply. ... In Nomad Sand & Gravel Ltd., supra, the nature of the taxpayer's business did not give the taxpayer any on-going connection with its customers that would have allowed the taxpayer to demonstrate it had to provide future services. ... At page 318 (D.T.C. 6164) of his judgment, Décary, J. stated: The question is whether the debts at issue were in fact acquired ”... for the purpose of gaining or producing income from a business or property....” ...