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In Her Majesty the Queen v Morton Pascoe, [1975] CTC 656; 75 DTC 5427, a recent Federal Court of Appeal case cited by counsel for the respondent, Pratte, J, on page 658 [5428], defined “alimony or other allowance” as follows:. ». ...

Here follows a list of gifts made to the said daughters showing at the same time the taxable income of the deceased in the relevant years (the gifts shown in the aggregate amounts): Year Amount of Gift Taxable Income 1954 $ 2,500 $35,400 1955 2,000 32,500 1956 2,000 32,600 1957 4,000 33,500 1958 4,000 47,800 1959 4,000 54,100 1960 4,000 50,600 1961 4,000 54,000 1962 4,000 52,500 1963 4,000 54,600 1964 4,000 54,400 1965 4,000 54,800 1966 20,000 61,900 1967 21,000 23,900 In assessing the estate for estate tax purposes the Minister of National Revenue has, pursuant to paragraph 3(1)(c) of the Estate Tax Act, included in the estate the gifts shown above as being made in the years 1965, 1966 and 1967 and has allowed a deduction of $4,000 under paragraph 7(1)(e) of the Estate Tax Act. ...

(signed) Robert Bastien Robert BASTIEN, economist, MBA Executive Vice-President SAPF Expert in tax reduction. ” Although it was purely hypothetical for the appellant, these advertising tactics impressed him sufficiently for him to commit himself to investing $5,000 in order to receive a capital cost allowance of $19,030. ...

I quote the section because it is short: 11. (1) Notwithstanding paragraphs (a), (b) and (h) of subsection (1) of section 12, the following amounts may be deducted in computing the income of a taxpayer for a taxation year: (ia) an amount paid by the taxpayer in the year as or on account of expenses incurred by him in attending, in connection with a business or profession carried on by him, not more than two conventions held during the year by a business or professional organization; There is no doubt that the conventions in question were held by business or professional organizations, nor is there any doubt—in fact, it is admitted—that the degree of success and study that Mr MacDonald has put into his vocation would qualify him as a professional within the meaning in my decision in Axler & Palmer Ltd v MNR, [1973] CTC 2167; 73 DTC 119. ...

The term “sham” has become quite common in income tax law and I quote, as the learned counsel for the Crown did, from the decision of Lord Justice Diplock in Snook v London & West Riding Investments Ltd, [1967] 1 All ER 518 at 528. ...

Again, it is agreed: that the deceased’s wife and one or more of his children survive him and are alive at all material times — (The executors named under the Will are the testator’s wife, his brother-in-law and his accountant);— that “the said Will instructs the executors and trustees to hold the residue of the estate in trust and to pay one half of the net revenue thereof to the deceased’s wife for life, the other half to be accumulated until such time as the deceased’s children reach the age of 25, at which time the accumulated revenue is to be distributed to these children and thereafter one-half of the net revenue shall be paid directly to them in equal shares”; and that upon the death of the wife of the testator, the capital of the estate is to be divided equally amongst the children, with the usual clauses pertaining thereto. ...

What in fact happened was that, in Western Canada, Mr Swift, through his companies, was obliged to buy or to take a minimum equity of 10% in the operating company — and in fact took considerably more through his own company and through his brother. ...

During the construction the partnership (Dr Besney, Mr Sorokin and Milton) encountered all kinds of difficulties — to name a few: the reduction of the first mortgage from $1 million to $900,000; the collapse of Atlantic Acceptance Corporation; the rental losses suffered by virtue of vacant apartments; and the fact that the building was not finished until about four months after the scheduled completion date. ...

The Concise Oxford Dictionary defines the word “throughout” as follows: Adv & Prep 1. ...

WHEREAS the Vendor alleges that on January 28, 1964, June 28, 1964, and October 28, 1964, he was the registered owner of all that certain parcel or tract of land being composed of lot 50-361, 362, 363, 364 & 365 of the Official Cadastre of the Parish of Montréal and whereas on the said days of January 29, 1964, June 29, 1964, and October 29, 1964, the said parcel or tract of land was taken by the Government of the Province of Quebec, represented by the Minister of Roads, according to the dispositions of article 1066V of the Code of Civil Procedure as per a notice of expropriation filed on January 29, 1964, June 29, 1964, and October 29, 1964, with the Registrar of Deed for the County of Montréal under numbers 1,724,679, 1,759,352 and 1,786,309. ...