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Is it not the most basic rule of construction that the grammatical and ordinary sense of the words be adhered to unless there is specific reason, — such as the context or the absurdity of the result arrived at — not to do so and the Board gives no reason here and indeed I see none (cf. ...

On this interpretation, subsection (7) could have application to taxpayers directly involved in contesting departmental interpretations before the Tariff Board or a Court or to those affected by an authoritative re-interpretation — this third group could include all taxpayers. ... A taxpayer who pays his taxes in good faith and under the general compulsion of the law should not be penalized for not challenging his Government’s right to the tax at every stage — annually, as recommended before us by counsel for the respondent. ... It provides that costs shall not be awarded — “unless the Court, in its discretion, for special reason, so orders” Since no special reasons were advanced, and none appear from the record, I would make no order respecting costs. ...

Each partnership borrowed the following capital amounts from the First National Bank of Chicago (‘FNBC’) to finance their real estate ventures: (a) PA- US $ 48,512,600; (b) JHA- US $2,387,400; and (c) CTA- US $ 3,200,000. ... In reaching this conclusion, the Tax Court Judge made the following findings: … I do not think that the fact that the appellant paid Society Hill’s obligation under the March 1, 983 agreement constituted a fulfilment of the appellant’s obligation under its guarantee to the Bank. ... T.D.), at 6221. 5 > Cadillac Fairview, supra note I at 409. 6 McHale v. ...

He said at page 468 (D.T.C. 5333): In general it may be observed that U.S. federal laws now seem to avoid using the word "import" to describe goods coming from Puerto Rico to the United States, referring to them instead as being “brought into the United States”, "coming to the United States”, or being for “ shipment to the United States”. ... In my judgment, it is impossible to assert that, within the meaning of that clause, the words “ if war breaks out” mean, “if war is recognised to have broken out by His Majesty's government recognizing it, if His Majesty's govern ment" had recognised that war had broken out, it may be — and I say no more — that a statement to that effect by His Majesty's government would be a matter which, even when dealing with a document of this kind, the court would be bound to accept. ...

Finally, the learned judge followed the decision of this Court in Johnson & Johnson Inc. v. ... This Court was faced with a similar issue in Johnson & Johnson Inc. v. ... Sanford & Brooks Co., 282 U.S. 359, 365 (1931). Nevertheless, strict adherence to an annual accounting system would create transactional inequities. ...

(Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081; Entreprises Kato Inc. v. ... (Customs & Excise) (1983), 18 Ex. C.R. 31, [1983] C.T.C. 416. Hugessen J.A. ... (Customs & Excise) (1983), 18 Ex. C.R. 31, [1983] C.T.C. 416, at page 33 (C.T.C. 418), stated: The ordinary and accepted meaning of the word "marchandises" (goods) is that of items circulated on the commercial market, items intended for sale. ...

Shofar Investment Corp. [4] when, at page 5849 of the report, he approved of what Jackett, C.J. had said on the appeal in in the following excerpts from his judgment: — What we are concerned with here is "gross profit”. ... In fact, "inventory" then and in 1978 was defined in similar terms, viz: — ''inventory" means a description of property the cost or value of which is relevant in computing a taxpayer's income from a business for a taxation year. ... It reads as follows: — 9.(1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. ...

The Purchaser shall, subject to the terms and conditions hereinafter set out, have the right to exercise the option hereby granted to him up to a maximum aggregate — 3,000 — shares during each of the first five years following the date hereof, provided that if the Purchaser shall fail to exercise his option up to such maximum aggregate in any year he shall have the right to exercise the option, in respect of the shares which he failed to exercise his option as aforesaid, at any time during the period of five years after the date hereof. 4. ... The Purchaser hereby acknowledges and agrees that the option to purchase — 13,850 — granted by the Company to the Purchaser under agreement dated January 2, 1974, as a result of a stock option plan established by the Company on November 8, 1973, shall, upon execution of this agreement by the Company and the Purchaser, be null and void and of no effect. ... As this appeal and the appeal in appeal No A-758-81, Anthony K Stephens v The Queen, were argued together, and as the parties have agreed that there should be one set of costs in the circumstances, I would award costs in this appeal but not in appeal No A-758-81. 1 'Appeal to Supreme Court of Canada dismissed 14/10/76 — No Reasons. 2 *See The Queen v Compagnie Immobilière BCN Ltée, [1979] 1 S.C.R. 865; [1979] CTC 71; 79 DTC 5068. ...

QUANTITY: The maximum quantity of crude oil to be sold and delivered under this agreement shall be as follows: August 1, 1968 through April 30, 1969 — 12,750 barrels per day. May 1, 1969 through April 30, 1970 — 14,550 barrels per day. May 1, 1970 through April 30, 1973 — 15,225 barrels per day. 4. ... DETERMINATION OF QUANTITY & QUALITY: The quantity and quality of crude oil sold and delivered hereunder shall be determined by Portland Pipe Line Corporation’s personnel, as inspector, unless either Buyer or Seller desires an independent inspector. ...

The first of these is Day & Ross Ltd. v. R., [1976] C.T.C. 707, 76 D.T.C. 6433 where Dubé J. held that fines paid by a trucking business for its trucks being loaded above weight restrictions were deductible as a business expense. ... Cullen J. appears to have held that these expenses, as in the Day & Ross case, were unavoidable and therefore they met the test of having been incurred for the purpose of earning income. ... It would frustrate the purposes of the penalties imposed by Parliament if after paying those penalties exigible by law a taxpayer were then able to share the cost of that penalty — and the higher his marginal rate of taxation the more he could share — with other taxpayers of Canada by treating it as a deductible expense and thus reducing his taxable income. ...