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In The Queen v Ken & Ray’s Collins Bay Supermarket Limited, [1975] CTC 504; 75 DTC 5346, Kerr, J decided that a somewhat similar management bonuses arrangement was contingent on the necessary funds being available. ...

The appellant produced cases, uncontested by the respondent, which have held interest expense to be deductible where the interest expense exceeds the income from property (Alberta & Southern Gas Co. v. ...

("Allarco '); and (c) 840 owned all of the issued shares of 348841 Alberta Ltd. ...

As I see it, the payment toward the mortgage can only be an allowance for maintenance of those for whom maintenance was intended under the agreements — that is, the defendant at least initially, and any children living at home after July 1982 pending completion of their education. ...

This principle is recognized in Interpretation Bulletin IT-410R, "Debt Obligations —— Accrued Interest on Transfer", which states (in paragraph 3), the amount, if any, of the interest determined for the purpose of subsection 20(14) is unaffected by either the prospects of its payment or non-payment or the nature or value of any consideration given by the transferee". ...

.: — I have had the advantage of reading the reasons for judgment prepared by my brother Urie, J.A. ...

These concerns arose from a series of events, including (a) his inability to cause the $20,000 cheque to be sent to Revenue Canada; (b) his failure to supply accurate statements showing the financial condition of the Corporation; (c) the fact that without Board authorization Jardine hired his wife as an employee of the Corporation; (d) his authorization to pay the sum of approximately $10,000 to Green, Haley & Pye for a restructuring report without receiving Board authorization; (e) his alleged verbal abuse of certain production employees of the Corporation; (f) his general habit of running the Corporation, making decisions and enforcing certain procedures without alerting the Board; and (g) his rosy projections of increased numbers of tourist buses and increased sales to customers, including a major customer, Jean Depot, which projections did not materialize. ...

., as he then was, in London & Thames Haven Oil Wharves Ltd. v. Attwool (1966), 43 T.C. 491, at page 515: The question whether a sum of money received by a trader ought to be taken into account in computing the profits of gains arising in any year from his trade is one which ought to be susceptible of solution by applying rational criteria. ...

The precise scope of the residual category- windfall gains — has proven problematic. ...

The Queen, [...] that argument cannot be rejected. Indeed, in that decision, as I read it, the Court held that the word "distribution" in Class 2 is used in a very general sense that encompasses what the jargon of the natural gas industry refers to as the transmission and the distribution of gas. ...