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.: — This is an appeal from an assessment dated December 22, 1995 issued by the Minister of National Revenue pursuant to section 160 of the Income Tax Act. ... Medland purchased a residence at 14582 — 18th Avenue, Surrey, British Columbia (the “Property”) for a purchase price of $115,000.00. ...

‘ This touches only $13,873.34 of the $86,310.57 net income in question. ... The will provides that the business of the estate shall be carried on and the earnings capitalized and accumulated, and the interest in effect compounded for 21 years after his death by the testator’s alter ego, the respondent, the trustee under his will, the statutory trustee under the Devolution of Estates Act, and the ‘‘ personal representative’’ pointed out as the taxable party by the Assess- ment Act, as I have said. ...

En effet j’y trouve: 15 semaines à $40.00 chacune, soit $ 600.00 37 semaines à $30.00 chacune, soit 1110.00 soit en tout $1710.00. ... Cette preuve du témoin Mahoney niant un écrit émanant de lui-même et portant sa signature serait en elle-même illégale et je pourrais la mettre de côté sans autre formalité si je n’avais plus que celà au dossier; car la défense a fait entendre le comptable Donat Viens, de la Maison Lucien Massé & Cie, qui jure qu’il a lui-même rempli 1’exhibit D-l qui porte la signature du témoin Mahoney, qu’il n’était pas alors signé et que d’habitude chaque employé se présente à son bureau, donne lui-même les détails qui l’intéressent, tel que le salaire gagné, le nom de son épouse et le nombre de ses enfants. ...

The learned trial Judge says in his judgment ([1944] C.T.C. at p. 35) that he finds it "‘necessary to find a name for such a contract’’, and that he would say 1 " it was one of lease and hire of work rather than a contract of agency’’. He adds: ‘‘ Looking at the contract as a whole, I am satisfied that the plaintiff is not an ‘agent’ or ‘servant' of the Crown.” ...

Canada (Director of Investigation & Research) (1990), 54 C.C.C. (3d) 417 (S.C.C.) ... Paragraph (14)(1) — page 11. Paragraph (17) — page 14. Paragraph (18) — page 14. ... A discussion of the plain view doctrine can be found in /?. v. Mousseau (1994), 94 C.C.C. (3d) 84 (Ont. ...

Prior to, and at all times material to this appeal, he established a " permanent establishment” in Canada, as defined in the Canada- United States tax conventions of 1942 and 1980. ... The document prepared by her, entitled "Allocation of Treatment & Administration Time Between Canada & The United States" was filed as Exhibit A-12. ... By adopting the method already described, he taxed a percentage of the appellant's “ manufacturing profit,” all of which was earned outside Saskatchewan. ...

In Ransom v MNR, [1967] CTC 346; 67 DTC 5235, Noël, J said this with reference to paragraph 6(l)(b) of the Act — it was paragraph 5(l)(b) at the time relevant to the Ransom decision — at page 359 [5243]: A reimbursement of an expense actually incurred in the course of the employment or of a loss actually incurred in the course of the employment is not an “allowance” within the meaning of the word in section 5(l)(b) as an allowance implies an amount paid in respect of some possible expense without any obligation to account. ...

Avery Jones, “Nothing Either Good or Bad, But Thinking Makes It So — The Mental Element in Anti-Avoidance Legislation” (1983) British Tax Review 9. ... More is to be gained by examining the second of the two requirements — reasonable expectation of profit. ... R., [1996] 1 S.C.R. 305, [1996] 1 C.T.C. 290, 96 D.T.C. 6121 at page 316 (C.T.C. 298, D.T.C. 6125); see also Dickson C.J. in Bronfman Trust, supra, at page 45 (C.T.C. 124, D.T.C. 5064). 9 See also Herald & Weekly Times Ltd., Re (Herald & Weekly Times Ltd. v. ...

The only difference between the 1991 version of subsection 80(4) and the transitional 1991 version is that the word "deducted" is employed in the latter version rather than the word “ deductible” after the words “ equal to the portion of the amount of such interest that was” appearing in the closing portion of these two versions. ...

According to Schedule 1 attached to the notice of assessment, that figure was arrived at as follows: Sale of land $2,307,330.00 Cost of land in 1960 $393,666.00 Capitalized carrying charges — 1960 to 1972 148,257.00 $ 541,923.00 1972 taxable income $1,765,407.00 Counsel for the plaintiff took two broad positions: (1) that the plaintiff’s dealing with the realty was not an adventure in the nature of trade, the submission being that it was acquired as an investment which resulted in a capital gain; (2) that the plaintiff was neither a resident of Canada nor a nonresident which carried on business in Canada and so was not taxable. ...