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Climac Hotels Ltd, B & C Hotels LTD v. Minister of National Revenue, [1985] 2 CTC 2312, 85 DTC 609 Brulé, TCJ [ORALLY]:—These two cases heard together, involved the purchases and sales of different hotel properties. As a result of these transactions the Minister reassessed Climac Hotels in its 1977 income tax year for the profit on the sale of a hotel as income rather than as a capital gain claimed, and in the case of B & C Hotels there were reassessments of its 1979 and 1980 income tax years on the same basis. ...

Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC) Couture, C.J.T.C. ... An agreement between C.A.C., referred to as the lessor, and Fortin & Moreau Inc. ... At the foot of the first page are the words: [Translation] “Part 3 — Lease (lessee's copy)". ...

Tubetest Service & Supply (1978) Limited, v. Her Majesty the Queen, [1994] 2 CTC 2320 O'Connor J.T.C.C. ... Chequing nil $ 2,375 Rec. General $ 998 $4,136 3. Only 20 per cent of the term deposits was used as security on outstanding bank loans with regard to the main business; 4. ... The company chose to reduce its taxable income to $200,000 by paying directors' and management fees and having the shareholders and management pay income taxes at high personal tax rates rather than have Tubetest Service & Supply (1978) Ltd. pay high corporate tax rates on taxable income over $200,000. ...

P & P Data Systems Inc. v. M.N.R., docket 98-204-UI Date: 19990412 Dockets: 98-204-UI; 98-29-CPP BETWEEN: P. & P. DATA SYSTEMS INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ...

Tillsonburg Glass & Mirror Limited v. Minister of National Revenue, [1985] 1 CTC 2345, 85 DTC 307 Christie, ACJTC:—This appeal is concerned with a claim by the appellant to entitlement to deduct farming losses in its 1980 taxation year in an amount in excess of $5,000. ... For the purposes of this appeal, it did: Kerr & Forbes v MNR, [1984] CTC 2071 at 2073; 84 DTC 1094 at 1096. ...

Quesnel & District Minor Hockey Assn. v. R., [1997] 3 C.T.C. 2260 Beaubier T.C.J.: 1 This appeal was heard at Prince George, British Columbia on April 30, 1997 pursuant to the Informal Procedure. ... Section 2: To control and operate Minor Hockey within the District of Quesnel; Section 3: To promote and inform the members of the Mutual Aid Fund, as a means of assistance to members injured in play, in authorized Hockey activities, to ensure the best possible safety standards are set and maintained by the Association. 7 After expenses, including referees' and linesmen's pay, the concession netted the following seasonal income: 1990-1 $ 3,070.27 1991-2 19,312.51 1992-3 5,573.29 1993-4 1,055.53 The concession posted advertisements for tournament breakfasts with which it had no connection. ...

Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC) Bowman, T.C.C.J. ... The definition of specified investment business” in paragraph 125(6)(h) of the Act applicable to the 1979, 1980 and 1981 taxation years was: (h) “ specified investment business” carried on by a corporation in a taxation year means a business (other than the business of leasing property other than real property) the principal purpose of which is to derive income from property, unless the corporation employs in the business throughout the year more than five full- time employees who are not specified shareholders of the corporation or persons related thereto. ... Ed Sinclair Construction & Supplies Ltd. Accrued management bonuses and accrued interest expenses I shall not repeat here the observations made in connection with the related appeal of Prosperous Investments Ltd. ...

Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576, [1987] 2 CTC 2311 (TCC) Brulé, T.C.J. ... Subsection 18(1) provides, in part, as follows: 18 (1) In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) (General limitation.) — an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; (b) (Capital outlay or loss.) — an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by this Part. ... Nomad Sand & Gravel Ltd., [1987] 2 C.T.C. 112; 87 D.T.C. 5343 decided by the Federal Court, Trial Division on July 16, 1987. ...

Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506, [1996] 2 CTC 2426 (TCC) Sarchuk J.T.C.C.:- This is an appeal by Will-Kare Paving & Contracting Limited from assessments of tax with respect to its 1988, 1989 and 1990 taxation years. ... To conclude otherwise would obscure the well-known distinction between manufacturing for the purpose of sale and manufacturing for the purpose of repair services, and be contrary to the plain intention of Parliament in enacting the legislation — an intention which the authorities say a proper construction of legislation must give effect to.... ... Appeal dismissed. 1 Hawboldt, supra. 2 supra at page 414-15 (D.T.C. 5429). 3 supra. 4 supra. 5 Webster’s New World Dictionary (2nd College ed.) page 1129. 6 1988 Income Tax Act, subsection 127(9) “qualified property” 7 ^Hawboldt, supra at pages 344-45 (D.T.C. 6547-48) 8 * Black’s Law Dictionary, 6 ed., page 1192. ...

Joe’s & Company Ltd. v. Minister of National Revenue, [1986] 1 CTC 2123, 86 DTC 1073 Sarchuk, T.C.J.:—Joe's & Company Ltd. (Joe's) appeals from assessments to tax with respect to its 1974 and 1975 taxation years. ... More specifically: (i) 1377- 1385 Winnipeg Avenue — this property was acquired in 1971 and was first listed for sale on April 19, 1972. ...