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Income Tax Act, RSC 1952, c 148 — 5(1)(a) — Employee benefit. The appellant was an employee of IMC Ltd at Esterhazy, Saskatchewan. ... On this basis, I will summarize the facts and nature of the dispute as follows: The appellant was an employee of International Minerals & Chemical Corporation (Canada) Limited (referred to hereinafter as IMC) which operated a potash plant at Esterhazy, Saskatchewan, from approximately November 1961 to December 1968. ... In the alternative, he submits that the benefit — if any — should have been spread over the taxation years 1962 to 1967, in which case the Taxation Division should have collected the additional tax from IMC. ...

I may add that whereas at the end of 1966 the unpaid loans, according to the evidence of Mr I M Noble, the appellant’s secretarytreasurer, amounted to $1,152,000, ail became paid in 1970 — an indication that perhaps some, at least, of the loans involved were not so doubtful after all. ... Matters might improve or they might not — no one really knew. Nevertheless, as the loans evidently were much better, as such, than was believed to be the case during the years under review, I think that not much above the minimum level should be fixed and granted as a reserve. ... Accordingly — and this is why reference is made to the circumstance — the second filing fee of $15 should be refunded to the solicitors concerned forthwith; the initial deposit of $15 was sufficient. ...

(a) Les Entreprises Beaulieu Inc 2/66 — $22,476.93 A Billet Ltée 1/66 — $12,523.07 (b) the other companies claim none of the $35,000 This sum of $35,000 was to be distributed as follows: Les Entreprises Beaulieu Inc. $15,981.12 A. Billet Ltée — Amelotte Transport Inc. 4,004.32 Atlas Transport Inc. 10,115.34 La Cie de Forage Chomedey Ltée 2,239.54 Bernard Transport Inc. 2,659.68 The respondent disallowed the second election by claiming that one or more associated companies could not make more than one election in one taxation year. ... He refers the Board to the following cases: (1) Esson & Sons Ltd v MNR, [1967] 1 Ex CR 82; [1966] CTC 439; 66 DTC 5303, where the Honourable Mr Justice Thurlow said that the “taxation year” mentioned in subsection 39(3) includes the taxation year common to all the corporations; (2) Riverside Builders Supplies Lid v MNR, 26 Tax ABC 227; 61 DTC 189; see DTC headnote: The appeal was dismissed. ...

In 1964 and 1965 the firm of W D Love & Company did the appellant company's auditing. In 1966 and subsequently the firm of Clarkson, Gordon & Co became the auditors of the appellant company and Mr John Green of that firm was an important witness at the hearing of the appeal. 11 From Mr Green's testimony and from supporting documents the amount of $52,107.30 had theretofore been carried in the appellant's books as an asset but was considered by the new auditors to be uncollectable. The 1965 income tax return of the company was amended by the firm of Clarkson, Gordon & Co and the amount was written off as a bad debt in 1965 and claimed as an expense. 12 It is alleged by the appellant that the amount of $52,107.30 in accounts receivable arose as a result of sales of steel products made by the appellant to Greensteel Fabricators in 1963. ...

In summary, the garments could not be “manufactured” simply by virtue of the cutting and sewing process — the complete operation conducted by the appellant had to be examined and taken into account by the Board. ... Those operations (cutting and sewing in particular) are not part of the calculation base upon which the appellant can make its claim for the relevant deduction — and indeed the appellant is not claiming that they should be. ... The activities which comprise the labour cost of the calculation — the $1,056 at issue — were within the meaning and definition of “qualified activities” as outlined in Regulation 5202. ...

At all relevant times, Centenary Distillers Limited owned all of the issued and outstanding shares of Joseph E Seagram & Sons, Inc. 6. ... Army & Navy Department Store (Western) Ltd v MNR, [1953] CTC 293; 53 DTC 1185; 16. ... Webster’s Third New International Dictionary Unabridged—A Merriam-Webster G & C Merriam Co, Mass USA “belong”: “to be the property of a person or thing”. 1.c. ...

In conclusion, the following table sets out my views. 1971 Value 1976 Value Lot 14 $343,400 $486,744 Lot 13 75,650 131,904 Lot 12 — 157,914 Lot 10 — 44,000 $820,562 3.08 The basic figures of this computation were, in fact, confirmed by the respondent’s witness, Mr Innes James Mitchell, leasing officer of the Royal Bank of Canada who has been employed with the said bank for twenty-nine years. ... Law — Cases at Law — Analysis 4.01 Law The main provisions involved in the present case are sections 3, 38, 39, 40 and 53 of the Income Tax Act and sections 20 and 26 of the Income Tax Application Rules. ... J G Vicq, Farm Property Valuation in the Prairie Provinces, an article in the “Canadian Tax Journal’’, Vol 25, No 6 — November/December 1977; 15. ...

In the agreement of sale $30,000 was allocated to the value of the land and $173,000 to the value of the building (Schedule C — Exhibit A-2). ... Sterilization or spraying the processing sections of the plant with chlorine or iodine solutions — as indeed was done at one point by the appellant — causes the destruction of the bacteria linens and indeed all bacteria and makes the processing of good quality limburger or brine cured brick cheese impossible. ... The difference between the expected earnings from the plant with bacteria present as opposed to earnings without the bacteria — when no earnings would be realized but losses incurred — provides, Dr Finlay suggests, an estimate of the economic value of bacteria in a cheese plant. ...

Heath & Sherwood Drilling Limited v MNR, [1971] Tax ABC 518; 71 DTC 338; 3. ... MNR v Howson & Howson Ltd et al, [1970] CTC 36; 70 DTC 6055; 18. Alpine Furniture Company Limited et al v MNR, [1968] CTC 532; 68 DTC 5338; 19. ... Counsel for the respondent himself recognized this in his argument. 5.3.2.4 In 1969 the taxable income of Les Presses ($20,379) and of the Institut ($11,318.99 — paras 4.25 and 4.26) did not total the amount of $35,000 stated in s 39 as being taxable at the lower rate of 18%. ...

In Marreco & Others v Richardson, the issue revolved around the question of whether the action was statute barred. ... The only area where I am aware that the Marreco case has not been followed is in bankruptcy cases, eg, re Hone & re Potter. ... Then he referred the Board to a decision already cited by the appellants in re Bankruptcy of G & G Equipment Co Ltd, 74 DTC 6407 to say that the appeals should be dismissed. ...