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The Queen is indivisible and wears the same crown in civil or criminal proceedings. [2] + There is jurisprudence to the effect that convictions in criminal proceedings constitute an estoppel in civil proceedings on the same subject-matter. ...

He observed [at page 291 (D.T.C. 6259)] that the Shorter Oxford English Dictionary defines "principal" as “the chief, main, or most important thing, part, point or element” and he commented [at page 290 (D.T.C. 6258]) that: The cases have held that the question of “ principal business” is a question of fact to be determined by an examination and comparison of all the facts concerning each of the various types of business in which the company is engaged. [4] In Sogemines, the predecessor corporation had as its object and purpose the carrying on of an investment business, it had only one part-time employee and no office or telephone listing, and it owned no mining equipment. ...

Nor is there any such evidence respecting his accountants Ernst & Young. ...

His total investment was just under $200,000. 2 + Warren thought, at the time, the three year period ran from the end of the contract term. ...

The following amounts were paid by him: Mortgage $2,148.00 Taxes 655.99 Water & sewer 151.50 Cablevision 59.40 Total $3,014.89 The respondent claimed as a deduction in the computation of his taxable income for the 1975 taxation year the sum of $1,256.20, which is 10/12 of 1/2 of the above total, the decree nisi having been granted in March 1975. ...

It is a substantive doctrine that goes to a determination of the true ownership of the property — a matter that is germane in an income tax appeal where the Minister of National Revenue seeks in effect, to cause a spouse's liability for tax to follow property that he says was owned by the husband and transferred to his wife. [2] This court has an obligation in such a dispute to determine the true ownership. [3] The appeal is allowed with costs and the assessment referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that immediately prior to the transfer of the three properties to her by her husband the appellant had a 50 per cent beneficial interest in the properties. ...

The notice of appeal read in part: — In calculating its tax for the years referred to in paragraph 1 hereof, the appellant deducted from its tax otherwise payable, an amount with respect to its manufacturing and processing profits pursuant to the provisions of section 125.1 of the Income Tax Act, (the "Act"), and an investment tax credit of 7% pursuant to section 127 of the Act. ...

This is confirmed by Exhibit R-l which is a detailed letter from Revenue Canada in Toronto to Richter & Partners, the receiver, dated May 6, 1983. ...

The term ‘‘uncertified progress claims” as used herein, means progress claims for which architect’s certificates have not yet issued. 2 *lt seems clear from the Co/ford judgment that “holdback” as used therein is used in the wider sense and includes “uncertified progress claims”. 3 TSaid paragraph 85B(1)(b) as it applied to the taxation year 1953 reads as follows: 85B. (1) In computing the income of a taxpayer for a taxation year, (b) every amount receivable in respect of property sold or services rendered in the course of the business in the year shall be included notwithstanding that the amount is not receivable until a subsequent year unless the method adopted by the taxpayer for computing income from the business and accepted for the purpose of this Part does not require him to include any amount receiv able in computing his income for a taxation year unless it has been received in the year; Note: The said paragraph applies also to the taxation year herein under review, ie, — 1968. 4 *l use the phrase “at law having regard to the Co/ford decision. ...

In 1982 the plaintiff received accounts for and paid legal fees as follows: Billed Paid Paid Balance Arbitration $14,241.25 $4,497.74 $ 9,743.51 Labour Relations Board Proceedings 13,896.61 80.50 13,816.15 Unrelated Matters 11,503.75 3,132.42 8,371.33 Total Amount Billed $39,641.65 $7,710.66 $31,930.99 The sum of $4497.74 was paid directly by the plaintiff's employer to the lawyer. ...