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.: — 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. ...

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....” ...

McKean & Archibald Randolf, [1876] 16 N.B.R. 299; 3. M.N.R. v. Wardean Drilling Ltd., [1969] 2 Ex. ...

.: — In 1978, François Prévost In (FPI) operated a real estate brokerage business in Québec. ...

That was the reasoning adopted by the Supreme Court of Canada in Steer, supra, and in Stewart & Morrison Ltd. v. ...

This surely would include repeatable experiments in which the steps, the various changes made and the results are carefully noted. 1 lt reads: 194. (2) In this Act, the “Part VIII refund" of a corporation for a taxation year means an amount equal to the lesser of (a) the aggregate of (i) the amount, if any, by which the scientific research and experimental development tax credit of the corporation for the year exceeds the amount, if any, deducted by it under subsection 127.3(1) from its tax otherwise payable under Part I for the year, and (ii) such amount as the corporation may claim, not exceeding 50% of the amount, if any, by which (A) the aggregate of all expenditures made by it after April 19, 1983 and in the year or the immediately preceding taxation year each of which is an expenditure (other than an expenditure prescribed for the purposes of the definition “ qualified expenditure" in subsection 127(9) claimed under paragraph 37(1)(a) or (b) to the extent that such expenditure is specified by the corporation in its return of income under Part I for the year exceeds the aggregate of (B) the aggregate of all expenditures each of which is an expenditure made by it in the immediately preceding taxation year, to the extent that such expenditure was included in determining the aggregate under clause (A) and resulted in (I) a refund to it under this Part for the immediately precedingtaxa- tion year, (II) a deduction by it under subsection 37(1) for the immediately preceding taxation year, or (III) a deduction by it under subsection 127(5) for any taxation year, and (C) twice the portion of the aggregate of amounts each of which is an amount deducted by it in computing its income for the year or the immediately preceding taxation year under section 37.1 that can reason ably be considered to relate to expenditures that were included in determining the aggregate under clause (A); and (b) the refundable Part VIII tax on hand of the corporation at the end of the year. 2 information Circular 86-4R was issued on September 25, 1987. 3 As will be seen from what has already been said in relation to Professor Snelgrove's evidence, the three criteria referred to in paragraph 2.10 of 1C86-4R2 are the criterion of scientific or technological advancement, the criterion of technologi cal uncertainty and the criterion of scientific and technical content. ...

Appeal dismissed. 1 The exact date of the approval of the loan by CIBC is not known other than it was sometime after June 13, 1985. 2 Thorne, Ernst & Whinney and Thorne, Riddell which are referred to in certain docu ments are predecessors of Peat, Marwick, Thorne. 3 By consent of both parties copies of the originals were filed. 4 Such as, inter alia, a failure to give notice of the redemption to Fantasy as required by clause 31.7(b) of theAppellant's articles; a failure to make payment of "a sum equal to the redemption” as required, cancel the shares or entry of the transaction in the share register. ...

Orkin & An. (1935, A.D. 18).) It is inappropriate to speak about "reducing" a "thought" or reducing a mental process. ...