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Justice Rouleau was sufficient, obviously, to convince him “... that the collection of all or any part of an amount assessed in respect of a taxpayer would be jeopardized by a delay in the collection of that amount,...” even though the amount, being the only amount apparently available for collection to the knowledge of the Minister, was already in the hands of the Minister. 9 In R. v. ...

DATED: August 15, 2023 APPEARANCES: Souad Akouz For The Applicant (ON HER OWN BEHALF) Anne-Élizabeth Morin For The Respondent SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec For The Respondent   ...

The down payment came from the plaintiffs savings, a loan from his father-in-law and a loan (?) ... One cannot classify a significant proportion of the expenses as what might be called “start-up” expenses — many are of an ongoing nature. ...

At the very top there are the words “Inventory — 1 horse Stone Manor; cost: $28,000 U.S.”. ... As Lord Justice Clerk so aptly said in deciding whether the gain from the sale of certain shares amounted to a profit from a business taxable as income or was merely a (then) untaxable capital gain in the case of Californian Copper Syndicate v Harris (1904), 5 TC 159 (Ct of Sess) at 166: What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being — Is the sum of gain that has been made a mere enhance- ment of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making? ...

Union Holdings Outside Edmonton 1969 still quarter held section 9. 137th & 127th Streets 1971 685 acres 10. (50% interest) 1971 13.78 acres 11. ... With regard to the buying, leasing and selling of lands being included in the objects of the company, it is of some importance to note the principle that, where the type of activity engaged in is that contemplated in the letters patent of either a public or a private company, although not conclusive evidence, this might well constitute prima facie evidence that, or at least, an indication that the profit derived from the activity is from the ordinary business of the company (see Anderson Logging Co. v The King, [1917-27] CTC 198; 52 DTC 1209, and The Queen & Metcalfe Carpark Ltd v MNR, [1973] CTC 810. ...

Doane & Company, who was referred to them as a tax expert to discuss, among other things, tax treatment of a housing loan from Canam. ... The shares were lodged at that time with the stock brokerage firm of Walwyn, Stodgell, Cochrane & Murray (hereinafter "Walwyn, Stodgell"). ...

In the present case the sum was paid in reference to a principal sum — that part of the plaintiff's salary to which she had become entitled during the 1980 year but which had not been paid to her during that time. ... It is open to the parties to govern their relationship by retroactive agreements: Trollope & Colls et al v Atomic Power Constructions, Ltd, [1962] 3 All ER 1035. ...

.: — Relief Sought This is an appeal from the assessments by the Minister of National Revenue in respect of the plaintiff's 1980 and 1981 taxation years by which the Minister added to the plaintiff's income the amounts of $31,395 in respect of 1980, and $154,000 in respect of 1981. ... The appeal will therefore be allowed with costs and the reassessments of the plaintiff's income for taxation years 1980 and 1981 will be referred back to the M.N.R. for reconsideration and reassessment on the basis that the amounts of $31,395 in 1980 and $ 154,000 in 1981 were not income. ...

So was its obligation to rebate royalties to Simon & Shuster. An account set up to provide for those contingent liabilities whether by way of a provision for returns and allowances on its balance sheet or a deduction from earnings in the calculation of its taxable income was a contingent account within the meaning of paragraph 12(1)(e). ... & Co. Ltd. v. Federal Commissioner of Taxation, 12 A.L.R. 593; and Nowegi- jick v. ...

Counsel for the defendant contends that there are instances where earth materials formed part of what were held to be structures, and he cites several cases to support this submission: Moran & Son Limited v. ... The New Brunswick case of Acadian Pulp & Paper Ltd. v. Minister of Municipal Affairs (1973), 6 N.B.R. (2d) 755 (C.A.) is closely on point. ...