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"' In either case, of course, what is contemplated is not the mere physical act of extraction of ore or of extraction of ore and processing of the ore. ... M.N.R., supra, at page 232 [S.C.R.]: What is exempt under the latter section [subsection 83(5)] is “ income derived from the operation of a mine.” ...

.: — Introduction This is an appeal from a decision of the Tax Court of Canada (Sarchuk J.T.C.C.) dated December 3, 1990 dismissing the plaintiffs appeal. ... & E. Ency. of Law, 2nd ed., vol. 26; tit. “Statutes,” pages 689-90: Provision in regard to the assessment and collection of taxes, and the measures preliminary thereto which are intended for the protection of the taxpayer, to ensure an equality of taxation, and to prevent a sacrifice of his property, are mandatory; while, on the other hand, those intended simply for the guidance of the officers and to promote the efficiency of their work are directory. ...

See Grover & lacobucci, Materials on Canadian Income Tax (5th ed., 1983, pp. 62-65). ... In other words, if there be admissible, in any statute, what is called equitable construction, certainly such a construction is not admissible in a taxing statute where you simply adhere to the words of the statute.' — cited with approval in this Court in The King v. ...

Hughes & Co. Holdings Ltd., (1994), 94 D.T.C. 6511 (Fed. T.D.), is the only case that deals with the term “part- time employee”. ... This interpretation is in accordance with the definition found in the Dictionary of Canadian Law, Dukelow & Nuse, Carswell, referred to in R. v. ...

The objects of the society are — (a) To provide for the recreation of the members and to promote and afford opportunity for friendly and social activities. ... I therefore summarise my conclusions in relation to trusts for political purposes as follows. (1) Even if it otherwise appears to fall within the spirit and intendment of the preamble to the Statute of Elizabeth, a trust for political purposes falling within the spirit of Lord Parker’s pronouncement in Bowman's case can never be regarded as being for the public benefit in the manner which the law regards as charitable. (2) Trusts for political purposes falling within the spirit of this pronouncement include, inter alia, trusts of which a direct and principal purpose is either — (i) to further the interests of a particular political party; or (ii) to procure changes in the laws of this country; or (iii) to procure changes in the laws of a foreign country; or (iv) to procure a reversal of government policy or of particular decisions of governmental authorities in this country; or (v) to procure a reversal of government policy or of particular decisions of governmental authorities in a foreign country. ...

That’s a very difficult question because from a planning point of view, we might have been — might give you one answer, but a political view would be another answer. ... M.N.R., [1984] C.T.C. 2674, 84 D.T.C. 1548 (T.C.C.), at page 2676 (D.T.C. 1549), best describes my response to the appellant’s claim: I am not persuaded the relevant section [54(c)] of the Income Tax Act permits of the view espoused by this taxpayer — that merely because he resided in a housing unit on the property, and used the balance of the property in one way or another to enhance the utility and attractiveness of that domestic living style, he can expand the boundaries of his housing unit to the parameters of the natural domain desired in his appeal. ...

This same passage was quoted with approval by Hall, J speaking for the Supreme Court of Canada in MNR v Dworkin Furs (Pembroke) Ltd, et al, [1967] S.C.R. 223; [1967] CTC 50; 67 DTC 5035, at 227 [52, 5036]: The word controlled as used in this subsection (subsection 39(4) which he had reproduced immediately above — my insertion) was held by Jackett, P to mean de jure control and not de facto control and with this I agree. ... In Floor & Wall Covering Distributors Limited and Vina-Rug (Canada) Limited v MNR, [1967] 1 Ex CR 390; [1966] CTC 566; 66 DTC 5373, Gibson, J said that “control” in subsection 39(4):... means the right to control by ownership of voting shares, not de facto control. ...

.: — Introduction This is an application for prohibition to prohibit the respondent Minister from demanding information from the applicant under paragraph 231.2(1)(a) of the Income Tax Act, for an order directing the Minister to return any documents or information already obtained under that paragraph and prohibiting him from communicating any knowledge of such information to any other person; and for any other order as may seem just, including as an alternative an order that the applicant be allowed to deposit any further information demanded of him with the Court in a sealed package not to be opened until certain criminal charges against him have been disposed of. ... The Supreme Court of Canada confirmed this in James Richardson & Sons, Limited v. ...

With respect to the expression “ substantially all”, these words, as used in another section of the Act, were interpreted in Wardean Drilling v. ... In Interpretation Bulletin IT-151, the Department of National Revenue has expressed the view that “ all or substantially all” in the context of subparagraph 37(7)(c)(ii) of the Act means at least 90 per cent. ...

The plaintiff expended 2 / years in arduous labour plus a substantial outlay for materials to restore the house following upon which he embarked upon the remodelling and restoration of the barns (contained in a single building) and the installation of equipment essential to the hog farrow to finish farming operatr *s he was undertaking. ... In addition to his labour a great part of his savings from the prior years as well as the proceeds of the sale of his former home in Port Hope, Ontario, went into this enterprise — a total of $16,000 of which $13,000 was his own and the small balance borrowed from a credit union. ...