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., M & B Trading and Congregation Oir Hachaim set out in the statements required under (1); 3. The relationship which exists between Traitement d'Aluminium Montreal Inc. and Carroll Alloys and Metal Inc., Chicago, Illinois and M & B Trading, New York, New York as well as with their principal shareholders Nathan and Lea Muller, and Chaim Landau respectively; 4. The reasons in regards to payments from Carroll Alloys and Metals Inc. and M & B Trading to Traitement d’Aluminium Montreal Inc. ...

To this evidence must be added the facts of an appeal instituted by a certain André Côté from an assessment for the 1985 taxation year in which the Minister added $6,110 to his income, an amount which had been indicated on a T4 supplementary slip produced by Dunn & Benoît. ... In the two situations of Côté and Barbeau, the income of those appellants had been increased in the assessments based on the information indicated on the T4 slips provided by the shareholders of Dunn & Benoît, and the Minister conceded in the consents to judgment that that information was false. and went on, at pages 15 to 16: What happened to the amounts recorded on the T4 slips prepared by Benoît for the employees Côté and Barbeau and which were in addition to those admitted in the consents to judgment? ... A judge simply does not have any ex officio knowledge of what he learned in another case (see Sopinka, Lederman & Bryant, The Law of Evidence in Canada, Butterworths, Toronto, 1992, page 985) and he is failing greatly in his duty of neutrality if he makes use of such knowledge (see Ducharme, Précis de la preuve, 3d ed., Wilson and Lafleur, Montréal, 1986, page 17). ...

In the alternative, the appellants seek an order limiting “... the matter of the appeal to those matters put in issue by the respondent before the learned Trial Judge at the said hearing”. Subject appeal is from orders of certiorari and prohibition granted by the Trial Division on September 4, 1986 in the following particulars: (a) the determination by the appellant Minister purporting to assess income tax as owing by the respondent and the document dated June 13, 1985, and headed "Notice of Assessment" and relating to the taxes said to be owing are quashed; (b) the decision by the appellant Minister to issue a "Requirement to Pay” dated March 18, 1986, pursuant to section 224 of the Income Tax Act and in respect of income tax allegedly owing by the respondent together with the document itself which were delivered to the Royal Bank of Canada are quashed; (c) a similar decision and a similar document to those in (b) supra, which were delivered to the Canada Permanent Trust are also quashed; (d) a decision by the appellant Minister to issue a certificate pursuant to section 223 of the Income Tax Act respecting income tax allegedly owing by the respondent together with the instrument itself are quashed; and (e) the appellant Minister and everyone under his direction and control are prohibited from continuing with collection proceedings or actions against the respondent ”... until it is lawful and fair to do — one certain criterion for which being lawful assessment of Part VIII tax actually found and assessed to be owing, upon assessment of tax in regard to applicant's filed return for its taxation year ended February 28, 1986”. ...

In her income tax return for the 1985 taxation year the taxpayer claimed as a deduction in computing her taxable income a " non-capital loss of other years utilized in 1985" in an amount of $84,774, the effect of which was to reduce her federal tax payable to zero. ... Recognizing that the result contended for by the taxpayer is ” unusual” the learned trial judge nonetheless felt that it was proper because of the application of section 114. ... As the trial judge rightly pointed out a deduction under subsection 20(12) is relevant to the computation of ” income". ...

He referred the matter back to the Minister for reassessment “on the basis that the adjusted cost base (V-day value) of 'proceeds of disposition — contract settlement' is $830,000 rather than $280,425. ... It is, therefore, excluded by the definition, supra, — test number 6. ... (dissenting): — During its 1977 taxation year, the respondent received a sum of $830,000 from Naden Harbour Timber Ltd. in circumstances that are fully recounted in the reasons for judgment of my brother Urie. ...

., with whom Hudson, J. concurred, referred to three cases which did not turn on the language of the statutes there under consideration, and said: — However, as to the other two contentions, there are three decisions that may usefully be referred to. The first of these is Robert Addie & Sons' Colleries Ltd. v. ... The shares would have been worthless, well, half of that value would have been what we received — Q. ...

., concurring): — This application for judicial review of a decision of the Tax Court of Canada raises the question, once again, of the applicability and effect of subsection 56(2) of the Income Tax Act (“the Act”). [1] The relevant facts are not in dispute. ... Jones wanted the property as part of a large development he was pursuing in order to create an “auto mall” — a major car sales centre. ... There will be cases — some were enumerated in Smith, at page 261 (D.T.C. 5355) — where the nature of the benefit conferred or the circumstances of a transaction will speak for themselves and be such as to render obvious the purpose of the taxpayer. ...

In the broadest sense. 1 mean, I think when — I think I considered that the money was more. ... And this was calculated — and I use "calculated" in the very broad sense — based on, among other things, the loss of the stock option and the lost income? ... London & Thames and Manley, supra, dealt with damages compensating for loss of income by traders. ...

Macdonald proposed to introduce a cigarette called “More” and Benson & Hedges a cigareiie called “Plus”. ... Both Macdonald and Benson & Hedges approached the Department separately, without notice to each other or the other members of the industry. ... Some time around the end of June or the beginning of July, officials in the Department agreed to adopt the view urged by Macdonald and Benson & Hedges, and these companies were so advised. ...

In 1969 the respondent company — a Quebec family company engaged in the manufacture of feed and raising of turkeys in St-Pie, a village near Montreal — borrowed $300,000 from the Industrial Development Bank to purchase a piece of land and construct buildings to be used in expanding its operations. ... It was submitted — and the Crown generously conceded — that the trust would have obtained an interest deduction if it had sold assets to make the capital allocation and borrowed to replace them. ...