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.: — In spite of the very able argument of Mr. Greene, we have not been persuaded that the judgment of the Trial Division was ill-founded. ...

.: — We have not been persuaded that the learned trial judge has committed any error that would require the intervention of this Court. ...

.: — This is an appeal from a judgment of the Tax Court of Canada, dated 16 April, 1996, dismissing the appellant’s appeal from reassessments made under the Income Tax Act (the “Act”) for the taxation years ending 31 December, 1989, 1990 and 1991. ...

.: — This application has been heard at the same time as the application in court file A426/95. ...

.: — This is an appeal from a decision of the Tax Court of Canada dated December 31, 1993 which dismissed the appellant taxpayer’s appeal from a reassessment of income tax for the 1986 taxation year. ...

Notwithstanding that the order in question may be viewed as a procedural ruling (Saint John Shipbuilding & Dry Dock Co. v. ...

His essential and overall finding that the agreement was not a mere “stand still agreement” or an “agreement merely not to pursue,” as contended by counsel, but rather a final one, that was meant to “settle the matter” definitely “a finding that involved, not only a careful analysis of the wording of the agreement and the inter-relation of its various clauses, but also an assessment of the intention of the parties drawn from the factual circumstances and their statements at trial ” cannot be reviewed by us without compelling reasons. ...

A Well, I got a frantic call one night about — I remember it was just before we went home so I figured it was about five o’clock at night — from the Department, and in the first place I was surprised because I didn’t know they worked that late. ... The short answer to that contention is, I think, that the wording of subsection 44(7.1) of the Act — “paid or overpaid in error, whether by reason of mistake of fact or law or otherwise” — makes it plain that “error” in paragraph 44(1)(c) is to be understood as including mistake of law as well as mistake of fact. ... This Court also attached importance to the concluding words of subsection 44(2) — “to the importer, transferee, manufacturer, producer, wholesaler, jobber or other dealer as the case may require” — as indicating in its opinion why the subsection should be construed as conferring a discretion. ...

Lawrence Market on a Saturday morning, some historic sites — Old Fort York and the Marine Museum, as well as visiting in homes all over the city and area. ... In addition to the Steering Committee and the membership — who joined them at a reception one evening at the Heliconian Club — they met Rotarians, members of the Canada/USSR Association, city administrators, teachers and students at Jarvis Collegiate, our Mayor and some members of Council and representatives of a number of Toronto peace groups. ... So, while a "foundation" will be entitled to registration as a "charity" as soon as the purposes for the pursuit of which the administrators or trustees are mandated and empowered to distribute money from its fund are "charitable" — a fact that can be determined only by considering the document by which the institution was set up — an "organization" will be entitled to be registered as a charity only if its activities are and remain charitable — a condition which requires an examination of what its members actually do. ...

I must now ask myself this question — is it any different from the taxpayer's plan in Neonex? ... I also agree with the trial judge that the legal expenses at issue herein — those incurred in an effort to complete the takeover and those incurred in seeking compensation in lieu of shares — were outlays associated with an investment transaction and thus were made on capital account. ... Now, it is quite true that in arriving at the profits or gains of a business you are not entitled, simply because — for what are likely quite prudent reasons — you either consolidate your business by not paying the profit away or enter into new speculations or increase your plant and so on — you are not entitled on that account to say that what was a profit is a profit no more. ...