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., [1986] 1 C.T.C. 2262, 86 D.T.C. 1214, as well as Les Conventions entre actionnaires, Editions Wilson & Lafleur, Martel Ltée, 1985, under the authorship of Paul Martel. ...

Was the " expense" in question incurred by the taxpayer for the purpose of gaining or producing income from the business? ...

The passage reads as follows: [Tax convention liberally interpreted] The accepted principle appears to be that a taxing Act must be construed against either the Crown or the person sought to be charged, with perfect strictness — so far as the intention of Parliament is discoverable. ...

This argument, however, puts a very narrow interpretation on the words ”.... amount... received... in recognition of his long service" in the definition of "retiring allowance” in subsection 248(1) of the Income Tax Act. ...

While statements furnished to Mr & Mrs Herman showing the record of their respective contributions to September 30, 1967, give a break-down of the actual amounts contributed, and the interest accrued to that date on these contributions, this is not up to date to the date of their retirement, and in any event there is nothing to indicate what portion of the pension payments they receive each year results from payments contributed by them, and of course interest continues to accrue on the amounts in the fund; moreover Mr Herman testified that the payments have been increased since 1972 by an escalation for cost of living. ...

.: — Relief Requested This is an appeal against a reassessment by the defendant of the plaintiff's income tax for her 1982 taxation year, in respect of the gain realized by her in the disposition of Lot 77, Section 31, Nanaimo District, Gabriola Island, Plan 23760. ...

.: — The plaintiff, National Trust Company, is a financial institution, but not a bank. ...

in Corporate Management Tax Conference — 1995, Real Estate Transactions: Tax Planning for the Second Half of the 1990s (Toronto: Canadian Tax Foundation, 1996) 6:1 at 6:15-16, quoted in Tonn at 6008. ...

The general principle of Wigmore v Thomas Summerson & Sons, Limited; Commissioners of Inland Revenue v Sir John Hubert Oakley, [1926] 1 KB 131, applies. ...

They did not “retire” in the common parlance sense of that word. 2 See, however, paragraph 36 of Exhibit 1 in this case. 3 + I do not know when the Minister first assessed and added into the defend ant’s income the amounts in question. ...