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Roberge & Fils Inc. v. The Queen, docket 95-3417-IT-G Date: 19980715 Docket: 95-3417-IT-G BETWEEN: eROBERGE & FILS INC., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Roberge & Fils acted only as a "vehicle" for the eventual transfer to 2745-8017 Québec Inc. What is more, the hypothec held by Roberge & Fils Inc. could have been challenged, as therefore could the giving in payment. ...

Roberge & Fils acted only as a “vehicle” for the eventual transfer to 2745-8017 Québec Inc. What is more, the hypothec held by Roberge & Fils Inc. could have been challenged, as therefore could the giving in payment. ... In a sale the extinction of the debt of the former creditor is only incidental, while in a viving in payment it i the primary result sought he ¢. ...

& J. Engineering Corporation v. Minister of National Revenue, [1992] 2 CTC 2235 Bonner, T.C.C.J. ... It took the position that the amounts received by it in 1985 and 1986 were ” pre-payments" or " deposits” on a contract which it had yet to complete. ... It was the position of counsel for the appellant that the deposit received by the appellant in 1985 [1] and the amounts received by it in 1986 under the CN contracts were ” prepayments". ...

& R. Asphalt Ltd. v. Minister of National Revenue, [1989] 1 CTC 2370 Sarchuk, T.CJ.:— The appellant L & R Asphalt Ltd. appeals from a reassessment of income tax for its 1985 taxation year. ... Nomad Sand & Gravel Ltd., [1987] 2 C.T.C. 112; 87 D.T.C. 5343. Counsel for the respondent argued that the Feeder does not in any reasonable fashion fit the definition of "property" set out in Class 22 of the Regulations. ... You don't use it to, say, move gravel from a pit to a location down the road, you don't hook it on to the back of the truck and — A. ...

Point Grey Golf & Country Club v. R., [1997] 1 CTC 2721, 97 DTC 854 Archambault J.T.C.C.: — These are appeals by Point Grey Golf & Country Club (“Point Grey”) from reassessments for income tax by the Minister of National Revenue (“Minister”) in respect of the 1989, 1990 and 1991 taxation years (“relevant taxation years”). ... Its by-laws provided that the objects of Point Grey was to conduct a golf and country club on the premises owned by Point Grey Golf & Country Club Limited. ...

Hadiken Concrete & Supply Ltd. v. R., [1998] 3 CTC 2777, 98 DTC 1984 Bell T.C.J.: Issue The issue in each of the appeals is whether a gain realized on disposition of an interest in a limestone quarry was on capital or income account. Facts At the commencement of his submissions, Respondent’s counsel said that if the sale by Lawrence Hadiken (“Lawrence”) was on capital account, then the sale by Hadiken Concrete & Supply Ltd. ... Concrete advertised in a number of journals as Selkirk Limestone Quarries giving its address, telephone numbers and hours of operation, including the following words FOR PICKUP & DELIVERY. ...

& M. Wood Products (1985) Ltd. v. R., 98 D.T.C. 1410, [1998] 2 C.T.C. 2701 Reeve, T.O., T.C.C.: 1 This taxation of costs was heard via conference call at 12:00 PM (PST) on Friday November 7, 1997. ... & M. Wood Products (1985) Ltd. Forest Management License Agreement, transcript of John Kennedy Davies and related undertakings, and financial statements for L & M Wood Products (1985) Ltd. 18 hours Preparation of quantitative schedules from the undertakings, including Schedule of Reforestation Costs, Schedule of Road Construction, Schedule of Volumes Harvested, Schedule of Areas Harvested, and Schedule of Dues 5 hours Analysis and reconciliation of data provided regarding the Renewal Fund in the accountant's working papers, Statement of Activity, financial statements, ledger cards and bank records for 1987 to 1990 12 hours Preparation of Evidence 36 hours Review of Evidence and background documents in preparation for Trial 8 hours Time spent by Kathryn Holgate 109 hours @$130 $14,170 Partner Consultation, Review of Evidence 9.5 hours @$200 $ 1,900 $16,070 12 In the case of Quintal v. ...

Ken & Jesie Degrace Family Trust v. R, [1999] 1 CTC 2807 Bonner T. ...

Van Lathing & Holding Co. v. R., [1996] 2 CTC 2008, [1997] DTC 129 Mogan J.T.C.C.: — In November 1987, the Appellant agreed to sell to Pan West Financial Inc. for $750,000 a 13-acre portion of Lot 7 (a parcel of land which will be described in greater detail below) in Langley, B.C. ... That was when — when I found out that they were going to go through with the sale of the land. ... That’s probably, you know, because he used the — personally I- then later on Mr. ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC) Bonner,T.C.J.: — The appellant appeals from assessments of income tax for the 1983, 1984 and 1985 taxation years. ...