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Richard Perren & Co. v. R., [1997] 2 CTC 2501, 97 DTC 1227 Brulé T.CJ.: These two appeals were heard on common evidence and involve a payment made to Richard Perren in 1989. ... In reassessing the Appellant’s income the Minister has included the following amounts: The Appellant understands that these personal reassessments relate to the Minister’s treatment of $142,800 ($120,000 U.S.) deposited in the U.S. dollar account of Richard Perren & Company Inc. ...

On March 31, 1982, an agreement was signed between D & B Oilfield Contracting Ltd., Sikanni Oilfield Construction Ltd. and Andrew Schuck. ... Central Mortgage & Housing Corp. v. Graham et al. (1973), 43 D.L.R. (3d) 686 (N.S.C.A.T.D.) ... Bank of Toronto, [1922] 3 W.W.R. 922 Robert Porter & Sons Limited v. ...

Supermarché Dubuc & Frère Inc. v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2215 (Informal Procedure) Garon, J.T.C.C. ... Dubuc stated that he began operating a grocery business on July 1, 1973 under the trade name Dubuc & Frères Enr. ... In the instant case the payment made by Métro-Richelieu was made to induce the taxpayer to conclude the fidelity agreement: — This payment was not associated with the purchase of property, whether equipment, rental improvements or otherwise. — This payment was not associated with expenses incurred or to be incurred by the taxpayer. — The taxpayer had absolute control over the amount received. — The taxpayer was not required to use the said amount for specific purposes. ...

At this time Oriole engaged the services of D & S Petroleum Consultants Ltd of Calgary to prepare a valuation of Oriole’s assets. ... There was also a deficiency problem in respect of the Blackfoot property which reduced the value of the assets by $400,000; as a result all the items in the transaction — the shares, employment contract and money payments — were renegotiated and all, including the employment contract, were reduced on a pro rata basis. ... Mr Penner, a chartered accountant practising as a partner with Thorne & Riddell in Calgary, was also called as a witness by the appellant. ...

Seaway-Levy Technical & Financial Limited v. Minister of National Revenue, [1991] 1 CTC 2260, 91 DTC 323 Sarchuk, T.C.J.:—The appeals of Seaway-Levy Technical & Financial Ltd. (Seaway) are from reassessments of tax with respect to its 1981, 1982 and 1983 taxation years. ... The appellant was incorporated in 1916 and until 1976 was known as Canadian Acme Screw & Gear Ltd. ...

It contains, inter alia, the following: LESSEE: Laurent Goulet & Fils Inc. ... Lagueux & Frères Inc., [1974] C.T.C. 687, 74 D.T.C. 6569 (F.C.T.D.); 5. ... Burns Sand & Gravel Ltd. v. M.N.R., [1968] Tax A.B.C. 218, 68 D.T.C. 226; 8. ...

Apl Oil & Gas Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2001 Margeson J.T.C.C.: — The Appellant filed an appeal from the reassessment dated August 14, 1991, number 3532072, with respect to its taxation year ending January 2, 1987. ... Attached herewith as Exhibit “B” is a copy of the August 17, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 7. ... Attached herewith as Exhibit “C” is a copy of the September 22, 1987 letter from Vennard Johannesen & Co. to Revenue Canada. 8. ...

Granby Construction & Equipment Ltd. v. Minister of National Revenue, [1989] 2 CTC 2239, 89 DTC 456 Lamarre Proulx, T.C.J. ... The question in issue is whether the appellant was right in establishing that debts owed to it by Amix Salvage & Sales Ltd. ... Harvey & Company Limited v. M.N.R., [1988] 1 C.T.C. 2209; 88 D.T.C. 1164, and Romualdo Berretti v. ...

Women in Film & Television Toronto Inc. v. M.N.R., docket 97-1402-UI Date: 19981209 Dockets: 97-1402-UI; 97-150-CPP BETWEEN: WOMEN IN FILM & TELEVISION TORONTO INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and MARGOT La ROCQUE, Intervenor. ... At that time WIFT-T employed one or two employees to carry out office / administrative functions for the organization. ... In a letter dated May 9, 1997 Revenue Canada, Appeals issued a letter (...) confirming their assessment. ...

Muir Cap & Regalia Limited v. Minister of National Revenue, 91 DTC 533, [1991] 1 CTC 2342 (TCC) Mogan, T.C.J. ... (the ” numbered company") and all of the former shareholders of the appellant took shares in the numbered company in the same proportion as their former shareholdings in the appellant. ... The ratio of current assets (including term deposits) to current liabilities in 1983 and 1984 is even more significant: 1983 1984 Term Deposits $245,977 $254,288 Payable to Parent Company $229,800 $169,698 Retained Earnings $119,218 $206,594 1983 1984 Current Assets $400,779 $448,728 Current Liabilities $ 38,699 $ 59,228 On the above facts, I cannot conclude that the appellants fund of term deposits, was“ employed and risked in the business” in the words of Le Dain, J. which were adopted by the Supreme Court of Canada in Ensite. ...