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Peisch & Company, whose offices are in three cities of Vermont and that the financial statement is addressed to the “Board of Directors, Slalom Sports Canada Ltd., Newport, Vermont” (the emphasis is mine). ... The order form, Exhibit P-9 and the Bordereau d’Expédition — Acknowledgment, Exhibit P-10, are two further examples leading me to believe that the defendant is only a distribution centre for the American parent company. ... Jay Norris Canada Inc., Federal Court — Trial Division, February 12, 1986, T—1921-82 (now reported at [1986] 1 C.T.C. 361), Mr. ...

In the case of Quebec Hydro-Electric Commission \/ The Deputy Minister of National Revenue for Customs and Excise, [19701 SCR 30; [1969] CTC 574; 69 DTC 5372, eleciricity was transformed from one type of alternating current to what was described in the findings of fact by the Tariff Board at pages 33 and 34 [576, 5374] as follows: By electromagnetic induction, initiated by the electrical energy of the primary alternating current, a new and separate alternating current is produced in the secondary winding of a transformer. ... The grounds for the distinction were that there was merely a change of pressure in the gas-pipe and all the appellant company did was to ",... merely cause the gas to pass, go, be conveyed or conducted from the high pressure pipes to lower pressure pipes, instead of producing a new current at a different voltage which was the function of the transformers as it was seen in the Hydro-Quebec case.” ... A bulk roll of foil weighs approximately 100 lbs and produces approximately 400 25 foot rolls which when packaged are in cases of 24 rolls per case, each 25 foot roll weighing approximately % of a pound. 12. ...

The appeal concerns three income tax reassessments each dated February 24, 1970 by which the following amounts were levied in respect of income for the taxation years of the appellant 1966, 1967 and 1968, that is to say: 1966 $ 51,783.04 1967 19,744.80 1968 35,895.18 The appellant was incorporated under the laws of Canada on January 21, 1957 and carries on business in Metropolitan Toronto as a manufacturer and distributor of conveyor systems under a license from the US Company. ... If the rights were acquired by a gift, Section 20(6)(c) applies and they are deemed to have been acquired at a cost equal to the fair market value at the time of the gift (J Bert MacDonald & Sons Limited v MNR, [1970] Ex CR 230; [1970] CTC 17; 70 DTC 6032; Ridge Securities Limited v CIR, [1964] 1 All ER 275; 44 TC 373; Petrotim Securities Limited v Ayres 41 TC 389; Jacgilden (Weston Hall) Limited v CIR, [1969] 3 All ER 1110; 45 TC 685). ... Tuxedo Holding Limited v MNR, [1959] CTC 172; 59 DTC 1102; [1959] Ex CR 390; J Bert MacDonald & Sons Limited v MNR, [1970] CTC 17; 70 DTC 6032; [1970] Ex CR 230; Craddock v Zevo Finance Co Limited, 27 TC 267). 8. ...

Accepting his accountant's advice he agreed to invest and immediately issued a cheque, as directed, to McRae & Associates in the amount of $4,929.29 and turned it over to Mr. ... The fact that Revenue Canada had or had not discharged the onus of satisfying the Court that the secretary of the company was “ authorized to receive and negotiate the cheque” was not discussed. ...

Salomon & Co., [1897] A.C. 22, it has been a well settled principle of company law that the mere holding of all the shares of a corporation does not lead to the conclusion that the business carried on by the company is the business of the shareholder. ... M.N.R., [1971] C.T.C. 640, 71 D.T.C. 5375 at page 660 (D.T.C. 5388) (F.C.T.D.); Gramophone & Typewriter Ltd. v. ...

Paving (sidewalks and bricks) $ 69,130 3. Retaining wall and concrete forming around pool $437,127 4. ... Statues and miscellaneous equipment $ 46,286 Landscaping is not defined in the Act. ...

Shefner & Co. Ltd., Bar Dan Realties Inc., Ariel Realties Inc., Ascot Construction Ltd. and Twenty-Five Corporation. ... Shefner's history of business activities in real estate transactions indicates the general course of conduct of a trader (Rudelier Ranches & Livestock Co. v. ...

The plaintiff was employed in a full-time capacity as plumbing supervisor by Zentil Plumbing & Heating Co. ... The plaintiff’s overall objective for his Orangeville tree farm is perhaps best illustrated by the following passage from his testimony: The only thing I can say, that when you spend money to create something, like in any business you have to put money up first, and that money should create income and profits at a later date, which in my case — like the pamphlet says there, I didn't go strictly by the pamphlet, but it explains there that it takes 34 [sic] years before you can have a big sale of trees. ...

In dealing with paragraph (b) on which the appeal was dismissed the trial judgment stated: Paragraph (a) seeks documents relating to negotiations between Hogg Robinson and Plaintiff as to acquisition of Richards, Melling & Co Ltd, and Paragraph (b) seeks documents as to the capital reorganization of that company. ... Despite this on November 25, 1983, the Department of National Revenue served a requirement pursuant to paragraph 23 l(3)(b) of the Income Tax Act to Clarkson, Gordon and Company requiring them to produce books and records for the working period 1976 to 1979 including all documents, working papers, invoices, statements, correspondence, memoranda and/or any other papers with respect to the abovenamed taxpayer (Hogg Robinson & Capel-Cure (Canada) Ltd) particularly with reference to an investment made by the above taxpayer in all types of shares in Melling Hogg Robinson Limited as stated in Note 5 with respect to the 1977 financial statement. ...

Make Model Year Serial # Licence Plate No Individual Price Ford Econoline 1969 E24AHD T.20.356 1575. 34787 I accept the evidence of Howard Tackaberry, heavy truck specialist for Ford of Canada, that the trucks had a trade-in value of $57,722 as. of March 31, 1972. ... FAIR VALUE OF ASSETS—VEHICLES, EQUIPMENT & INVENTORIES” as above, the Deputy Postmaster General went on to deal with: B. ...