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As of September 30, 1984 Lone Rock had “tax pools” as follows: Non-Capital Losses year ended September 30, 1981 $ 1,192,564 year ended September 30, 1981 ended September 30, 1982 589,192 year ended September 30,1982 Undepreciated Capital cost (UGC) $1,062,941 Undepreciated Capital cost ('UCC) Cumulative Canadian oil and gas property expense ('CCOGPE‘) $2,658,811 property expense (CCOGPE*) Cumulative Canadian Development Expense CCDE $ 32,641 Cumulative Canadian Development Expense (CCDE) Earned Depletion Base $ 136,162 Earned Depletion Base Attributable Canadian Royalty Income Balance $3,097,605 Attributable Canadian Royalty Income Balance 3. ... Bodrug 2 Bodrug & Son Acceptance Ltd. 424,220 99109 Canada Ltd. 1,192,360 Robert Edgar McLennan 22,955 Estate of Evan W.G. ... This is followed by signatures on behalf of Lone Rock and the shareholders thereof, namely, Bodrug & Son Acceptance Ltd., 99109 Canada Ltd. and the individuals Danford E.E. ...

She told him that she knew a Marc Levert, who acquired works of art at auctions and resold them at a low price — about 25 percent of their value. ... Lagueux & Frères Inc. (1974), 74 D.T.C. 6569 (Fed. T.D.), in which it was held that to determine the tax consequences of a transaction, the nature of the transaction must be determined under the civil law. ... Duguay [TRANSLATION] “was guilty of gross negligence, or even wilful blindness, in continuing year after year, for five years, to enter into the same kind of simultaneous transaction — paying 25 percent in exchange for a tax receipt, no matter what organization and property were involved — and in not wanting to see, in the case of Mr. ...

Subsection 118(1)(b) of the Act reads as follows: (1) For the purpose of computing the tax payable under this Part by an individual for a taxation year, there may be deducted an amount determined by the formula A x B where A is the appropriate percentage for the year, and B is the aggregate of (b) in the case of an individual not entitled to a deduction by reason of paragraph (a) who, at any time in the year, (i) is an unmarried person or a married person who neither supported nor lived with his spouse and is not supported by his spouse, and (ii) whether by himself or jointly with one or more other persons, maintains a self-contained domestic establishment (in which the individual lives) and actually supports therein a person who, at that time, is (A) except in the case of a child of the individual, resident in Canada, (B) wholly dependent for support on the individual, or the individual and such other person or persons, as the case may be, (C) related to the individual, and (D) except in the case of a parent or grandparent of the individual, either under 18 years of age or so dependent by reason of mental or physical infirmity, an amount equal to the aggregate of (iii) $6,000, and (iv) an amount determined by the formula $5,000 — (D — $500) where D is the greater of $500 and the income for the year of the dependent person; [Emphasis added] Subsection (1) of section 15 and section 1 of the Charter read as follows: 15(1) Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination and, in particular, without discrimination based on race, national or ethnic origin, colour, religion, sex, age or mental or physical disability. 1. ... The Attorney General of Canada, [1986] 1 C.T.C. 75, 85 D.T.C. 5561; Smith, Kline & French Laboratories Ltd. v. ...

Brehaut questions about a number of documents including an October, 1980 Detour Lake joint venture executive summary, a pamphlet prepared by the appellant entitled "The Mine Development Process, Campbell Red Lake 1980 Annual Report”, excerpts from a joint venture agreement dated December 29, 1982, Detour Lake Mine capital expenditures summary — 1984 and 1984 annual reports, 1985 annual report excerpts and other documents. ... Brehaut to a document entitled Detour Lake Mine Capital Expenditures Summary — 1984 showing actual expenditures of $8,783,784 for Phase II expansion underground and a figure of $9,334,460 shown as "Approved by J.V.” ... Justice Cartwright said, at page 601 (C.T.C. 212, D.T.C. 1152): For the appellant it is contended that the word “ mine” as used in clause (b) of subsection 74(1) means not "a portion of the earth containing mineral deposits" but rather “a mining concern taken as a whole, comprising mineral deposits, workings, equipment and machinery, capable of producing ore". and then accepted that contention. ...

.: — Issues The appeals of Dunblane Estates Ltd. concern its 1982 and 1983 taxation years. ... When taken with the information provided in letter form marked Exhibit A-5, and the summary contained in Exhibit A-4, the following summation of the sick leave accruals and payments is evident: NET PAYOUT FUND MONTHS TO ACCRUED PAID INCREASE PERCENTAGE BALANCE — 31 Aug. 81 (Journal Entry) $ 84,871.50 12 31 Aug. 82 $74,203.00 $47,838.50 $26,364.50 64% 111,236.00 6 28 Feb. 83 37,101.00 27,121.00 9,980.00 73 121,216.00 6 31 Aug. 83 35,757.89 26,964.85 8,793.04 75 *143,335.04 7 31 Mar. 84 34,078.35 34,133.39 (55.04) 100 143,280.00 12 31 Mar. 85 82,905.26 59,503.39 23,401.87 72 166,681.87 12 31 Mar. 86 75,498.57 47,619.06 27,879.51 63 194,561.38 12 31 Mar. 87 74,276.81 62,986.34 11,290.47 85 205,851.85 [*under appeal] This confirms that, notwithstanding an average 75 per cent pay-out rate calculated on an annual accrued/pay-out basis, the accrued liability was increasing. ...

., to be rendered — any amount received by the taxpayer in the year in the course of a business (1) that is on account of services not rendered or goods not delivered before the end of the year or that, for any other reason, may be regarded as not having been earned in the year or a previous year, or (ii) under an arrangement or understanding that it is repayable in whole or in part on the return or resale to the taxpayer of articles in or by means of which goods were delivered to a customer. ... I draw this inference from subparagraph 20(1)(m), which reads: 20(1) Notwithstanding paragraphs 18(1)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (m) Reserve in respect of certain goods and services — subject to subsection (6), where amounts described in paragraph 12(1)(a) have been included in computing the taxpayer’s income from a business for the year or a previous year, a reasonable amount as a reserve in respect of (i) goods that it is reasonably anticipated will have to be delivered after the end of the year, (ii) services that it is reasonably anticipated will have to be rendered after the end of the year, (iii) periods for which rent or other amounts for the possession or use of land or chattels have been paid in advance, or (iv) repayments under arrangements or understandings of the class described in subparagraph 12(1)(r/)(ii) that it is reasonably anticipated will have to be made after the end of the year on the return or resale to the taxpayer of articles other than bottles. ... Langan, Snell's Principles of Equity (London: Sweet & Maxwell, 1982) at 41. ...

In this calculation he looked at the billings achieved up to December 31st, 1991 and came up with a low goodwill value of $73,257.00 and a high goodwill value of $107,354.00 based on the Guthrie / Bonnatyne formula. [12] He considered valuations based upon the ICABC goodwill surveys and admitted that different interpretations could be placed upon schedule G depending upon the factors he looked at. ... On page 16 of his report he concluded that the valuation of the goodwill on the date in question based upon the different methods was as follows: (1) excess earnings method.- low, $49,100.00, high, $61,400.00. (2) Rule of thumb method-schedule F (A)- Exhibit A-2- low $65,900.00, high $82,400.00. (3) Githrie / Bonnatyne method,- low $73,300.00, high, $107,300.00 (4) ICABC surveys- low $74,400.00- high $86,800.00. (5) Actual retention rates method- low, $86,400.00, high, $98,800.00. (6) Future billings method- low, $83,600.00- high $92,100.00. (7) Discounted future cash flows method- low, $117,600.00, high, $147,500.00. [15] It was his position that the most appropriate method of calculating value was considered to be the rule of thumb calculations based on the ICABC surveys. [16] He was referred to the Respondent`s report and he said that he had reviewed it. ... Landry at page 3, the limitations of his report are set out by him when he said, "based on the information available to me in the restricted scope of my review, the attached calculations indicate that the estimated fair market value goodwill is within the range of $74,000.00 / $87,000.00. ...

At the request of — and I assume the direction of — the Mercantile Bank of Canada, Dwyer wrote the accounting firm of Thorne Riddell on January 14, 1985 asking that firm "to make a full and complete investigation of certain aspects of the business affairs of the company with a view to reporting to the Mercantile Bank of Canada concerning the same". ... Lassonde & Fils Inc. v. Mignon (1992), 17 C.B.R.(3d) 86 (C.S. Qué) at page 90. ...

In the years in question, he was fishing off the "Wally & Sisters" with a crew of five to six including himself. ... Powell & Company. The cheque register was kept at Stephenville and it was on the computer before 1990. ... In Andrew Paving & Engineering Ltd. et al. v. M.N.R., [1984] C.T.C. 2164, 84 D.T.C. 1157 (T.C.C.), it was held that where statutory provisions are open to two interpretations, the one to adopt is that which is just and reasonable rather than that which is neither. ...

The above excerpts of the oral argument advanced on behalf of both appellants must he considered with the submission made in the undated notice of appeal filed with the Court in file No. 86-1443(IT) by the appellant, Serafino Tiberio, in respect of the 1985 taxation year, which submission is couched in the following terms: "This claim is based on the Canadian Charter of Rights & Freedoms; in particular section 15, which does not allow discrimination based on age. ... The following excerpts from the judgment of Hugessen, J. in Smith, Kline & French Laboratories Ltd. v. ... If paragraph 122.2(2)(a) is invalid it falls, and in the absence of legislative action to fill the void it cannot be said that the appellant is, within the meaning of subsection 122.2(1), ”... an individual who has an eligible child... ...