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B B Fast & Sons Distributors LTD v. Minister of National Revenue, [1982] CTC 2002, 82 DTC 1017 Guy Tremblay:—This case was heard in Winnipeg, Manitoba on February 13, 1981. ... The Point at Issue The point at issue is whether or not the appellant, B B Fast & Sons Distributors Ltd and Willmar Window Industries Ltd were associated corporations during the 1975, 1976 and 1977 taxation years. ... H A Fawcett & Son, Limited v HMQ, [1979] CTC 303; 79 DTC 5224; affirmed by [1980] CTC 293; 80 DTC 6195; 10. ...

Ken & Ray’s Collins Bay Supermarket Limited v. Minister of National Revenue, [1974] CTC 2267 Judge K A Flanigan (orally: March 6, 1974):—This is an appeal by Ken & Ray’s Collins Bay Supermarket Limited against the reassessment of the Minister of National Revenue for the 1969 and 1970 taxation years. ... The evidence in this case has been given by Mr Partridge, an auditor with the firm of Thorne Gunn & Co, the auditors for the appellant company, and in his view sound accounting business practices were followed in setting up a new form of bookkeeping system when they accepted this company as one of their accounts. ...

Southco Holdings & Management Ltd. v. Minister of National Revenue, [1975] C.T.C. 2205, 75 D.T.C. 162 Roland St-Onge (orally: January 9, 1975): 1 This appeal is from a reassessment dated November 21, 1972, with respect to the 1969 taxation year. ... Chamberlain (HM Inspector of Taxes), 45 TC 92at 106, and I read: Therefore, the learned Judge held, as I understand it, that because it was a hedge against devaluation it was not a trading adventure; and, notwithstanding the other findings of the Commissioners, he held that, if they had rightly appreciated the facts, that was the conclusion to which (...) they must have come. ... And then, the learned judge of the Exchequer Court laid down the following positive guides at page 214 [1139] stating that a transaction is “an adventure in the nature of trade” (1) “... if a person deals with the commodity purchased by him in the same way as a dealer in it would ordinarily do”, and (2) if “the nature and quantity of the subject matter of the transaction may... exclude the possibility that its sale was the realization of an investment...”. 23 In the present appeals it cannot be said that the gold was acquired as an investment. ...

Saint John Shipbuilding & Dry Dock Co LTD v. Minister of National Revenue, [1976] CTC 2370, 76 DTC 1283 Delmer E Taylor:—This is an appeal from income tax assessments for the years 1971, 1972 and 1973. ... The following are quotations from Exhibit A-1: AUTOKON LICENSE AGREEMENT THIS AGREEMENT made this 8th day of April, 1971, BY AND BETWEEN: SAINT JOHN SHIPBUILDING & DRY DOCK CO, LTD, with head office in Saint John, New Brunswick, Canada, hereinafter called “the Subscriber”, of the one part, — and — COM/CODE CORPORATION, with executive offices locate dat 1812 K Street, NW, Washington, DC, USA, hereinafter called “the Company”, of the other part. ... Under the relevant section of the Act, 212(1)(d), it remains to determine if the payment falls within “... or a similar payment”. ...

Antares Oil & Gas LTD (In Liquidation) v. Minister of National Revenue, [1983] CTC 2157, 83 DTC 139 The Assistant Chairman:—Antares Oil & Gas Ltd (hereinafter referred to as the “appellant” or “Antares”) has appealed to this Board from assessments of income tax for the 1977 and 1978 taxation years. ...

Sivaco Wire & Nail Company, Industrial Fasteners LTD v. Minister of National Revenue, [1981] CTC 2081, 81 DTC 140 D E Taylor:—These are appeals heard on common evidence in the City of Montreal, Québec, against income tax assessments for the years 1972 to 1976 inclusive for Industrial Fasteners Ltd (hereinafter referred to as “industrial”) and for the years 1974,1975 and 1976 for Sivaco Wire & Nail Com- pany (hereinafter referred to as “Sivaco”). ...

Clarence Daigle & Fils Ltee v. Minister of National Revenue, [1981] CTC 2770 Roland St-Onge:—The appeal of the company, Clarence Daigle et Fils Ltée, came before me on July 8, 1981, in the city of Fredericton, New Brunswick, and the issue is whether the appellant is allowed to claim an investment tax credit, within the meaning of subsection 127(10) of the Income Tax Act, for a tractor and scarifier-tooth rake purchased in the appellant’s 1977 taxation year. ... The Taxpayer, CLARENCE DAIGLE & FILS LTÉE, (hereinafter referred to as the “Taxpayer”), is a Company incorporated under the laws of the Province of New Brunswick and at all times material to the appeal carried on business in the Province of New Brunswick. 2. ...

S & S Properties LTD v. Minister of National Revenue, [1977] CTC 2267 Roland St-Onge (orally: March 25, 1977):—The appeal of S & S Properties Ltd came before me on March 22, 1977 at the City of Victoria, British Columbia, and the question at issue is whether a gain earned in the appellant’s 1973 taxation year is taxable or not. ...

Kelly, Douglas & Company Limited v. Minister of National Revenue, [1976] CTC 2107 A W Prociuk (orally: October 31, 1975):—The appellant, Kelly, Douglas & Company Limited, appeals from the respondent’s reassessment of its income for the taxation year ended December 31, 1971, wherein the deduction of $53,331, representing the cost of its stationery and special forms on hand at the end of the year, from its income was disallowed on the ground that it was inventory within the meaning of subsection 14(2) and paragraph 139(1)(w) of the Income Tax Act then in force, and should be carried forward into the succeeding year. ...

Bates Construction & Development Corporation v. Minister of National Revenue, [1973] CTC 2277, 73 DTC 234 The Assistant Chairman:—The appeal is from a tax assessment for the 1969 taxation year. Counsel for the parties agreed on the following facts: The fiscal period of Bates Construction & Development Corporation (hereinafter called “Bates Construction”) ends on September 30. ...