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BCCA decision
In Re Taxation Act and Income Tax Act and in Re Assessments of Firestone Tire and Rubber Company of Canada, Limited., [1940-41] CTC 349
However, those sales are excluded from the present controversy, which concerns only ‘‘Firestone’’ products warehoused by the dis- tributor in Vancouver, and for which the distributor is under no liability to pay as long as it can show they remain in its warehouse. ... The agreement correctly describes itself as a " " distributor’s warehouse contract. ’ Nowhere in it does the dis- tributor agree to buy the warehoused goods. ...
BCCA decision
Minister of Finance of British Columbia v. Estate of Percival, Archibald, Woodward, [1971] CTC 341
His Lordship gave effect to that submission and dis missed the appeal. ...