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Shofar Investment Corp. [4] when, at page 5849 of the report, he approved of what Jackett, C.J. had said on the appeal in in the following excerpts from his judgment: — What we are concerned with here is "gross profit”. ... In fact, "inventory" then and in 1978 was defined in similar terms, viz: — ''inventory" means a description of property the cost or value of which is relevant in computing a taxpayer's income from a business for a taxation year. ... It reads as follows: — 9.(1) Subject to this Part, a taxpayer's income for a taxation year from a business or property is his profit therefrom for the year. ...

The Purchaser shall, subject to the terms and conditions hereinafter set out, have the right to exercise the option hereby granted to him up to a maximum aggregate — 3,000 — shares during each of the first five years following the date hereof, provided that if the Purchaser shall fail to exercise his option up to such maximum aggregate in any year he shall have the right to exercise the option, in respect of the shares which he failed to exercise his option as aforesaid, at any time during the period of five years after the date hereof. 4. ... The Purchaser hereby acknowledges and agrees that the option to purchase — 13,850 — granted by the Company to the Purchaser under agreement dated January 2, 1974, as a result of a stock option plan established by the Company on November 8, 1973, shall, upon execution of this agreement by the Company and the Purchaser, be null and void and of no effect. ... As this appeal and the appeal in appeal No A-758-81, Anthony K Stephens v The Queen, were argued together, and as the parties have agreed that there should be one set of costs in the circumstances, I would award costs in this appeal but not in appeal No A-758-81. 1 'Appeal to Supreme Court of Canada dismissed 14/10/76 — No Reasons. 2 *See The Queen v Compagnie Immobilière BCN Ltée, [1979] 1 S.C.R. 865; [1979] CTC 71; 79 DTC 5068. ...

QUANTITY: The maximum quantity of crude oil to be sold and delivered under this agreement shall be as follows: August 1, 1968 through April 30, 1969 — 12,750 barrels per day. May 1, 1969 through April 30, 1970 — 14,550 barrels per day. May 1, 1970 through April 30, 1973 — 15,225 barrels per day. 4. ... DETERMINATION OF QUANTITY & QUALITY: The quantity and quality of crude oil sold and delivered hereunder shall be determined by Portland Pipe Line Corporation’s personnel, as inspector, unless either Buyer or Seller desires an independent inspector. ...

The first of these is Day & Ross Ltd. v. R., [1976] C.T.C. 707, 76 D.T.C. 6433 where Dubé J. held that fines paid by a trucking business for its trucks being loaded above weight restrictions were deductible as a business expense. ... Cullen J. appears to have held that these expenses, as in the Day & Ross case, were unavoidable and therefore they met the test of having been incurred for the purpose of earning income. ... It would frustrate the purposes of the penalties imposed by Parliament if after paying those penalties exigible by law a taxpayer were then able to share the cost of that penalty — and the higher his marginal rate of taxation the more he could share — with other taxpayers of Canada by treating it as a deductible expense and thus reducing his taxable income. ...

[8] I $312,125.61 and the respondent’s position was that the proportion of the total estate tax deductible was $312,125.61 minus (a proportion of debts, funeral expenses, etc, and amounts [other than value of property passing on death] deductible under section 7) total value of property passing on death minus (debts, funeral expenses, etc, + all section 7 deductions):]: [9] According to the respondent’s calculation, the paragraph 11(1)(v) allowance in respect of the death benefit was $35,624.46. ... The executors equally have the right to apportion none of the $312,000 lump sum pension benefit to the lifetime annuity when, in fact: (i) 30% of such lump sum pension benefit were withheld and paid on account of income taxes; and (ii) the balance to pay Provincial Succession Duties and to obtain seizing of the Estate. + The lifetime annuity could only have come from the other assets of the Estate; not the pension fund, which was used for other purposes. ... I propose, therefore, to discuss the matter as though clause (B) were not in subparagraph (v)(i). + The word “property” acquires a special significance from its use in the Estate Tax Act. ...

Turpin, [1989] 1 S.C.R. 1296, 48 C.C.C. (3d) 8, 69 C.R. (3d) 97; Rudolf Wolff & Co. v. ... See S.C. 1990, c. 45, section 48. 2 See also the statement of McIntyre J., at page 180, where he cited with approval the judgment of my colleague Hugessen J. in Smith, Kline & French Laboratories Ltd. v. ... It is, of course, obvious that legislatures may — and to govern effectively — must treat individuals and groups in different ways. ...

Rayner & Keeler Ltd. (No. 2), [1967] A.C. 853 at 935; [1965] 2 All E.R. 536 at 565 which had been in turn cited with approval by Dickson, J. ... Rayner & Keeler Ltd. (No. 2), [1967] A.C. 853 at 935; [1966] 2 All C.R. 536 at 565 which were approved by the Supreme Court of Canada in Angle v. ... I will deal with those attacks seriatim. (1) It should again be noted that the certificate of conviction states that the respondent, ”... unlawfully did evade payment of taxes... by suppressing income in the sum of $60,000 for the taxation year 1973...”. ...

J.D.L. itself received the goods which it shipped to the respondent, from its U.S. parent, Deere & Comapny, on consignment in accordance with a written agreement between them. ... H.C.); Re Librairie & Tabagie Aston Inc.; St.-Georges v. Agence de Distribution Populaire Inc. (1980), 35 C.B.R. ... I conclude that the o ^ I? f consignment intended as security within the meaning of s. 2 of the PPSA and that, therefore, no registration or other compliance with that statute was required on the part of Anglo. ...

R. [1] ’, decided after the trial judgment in the present case. The provision in question in that case, subsection 55(2) of the Income Tax Act, required for its application that “one of the purposes” be to support a significant reduction in capital gain realized. ...

.: — The appeal raises two questions. 1. Were the amounts provided by the Government of Alberta to the respondent “assistance” as a grant, subsidy, forgiveable loan, deduction from tax, investment allowance or as any other form of assistance.... within the language of both subparagraph 12(l)(x)(iv) of the Income Tax Act, defining income, and of subsections 127(11.1) and 127(9) defining investment tax credits? ...