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., a mortgage company which closed up one year later;-1970: the purchase of farm acreage on Pender Island which was sold ten years later at $1 million gross profit; —1974: the formation of Canada-West Charters involving some half-dozen C & C 36 sailboats, chartered on a weekly basis, and which he sold in 1980; —1982: the purchase of property in Whistler, B.C., bearing the name Unique Resorts, which he sold a year later; and-1984: the establishment of Fern Press, involved in Northwest Art lithographs and prints, which he sold at a loss a year later. ...

. $100,000 at Toronto together with interest @ 11.5 per cent per annum. ...

Chairman Cardin made the following observations at page 2220 (D.T.C. 160): The evidence is that, in the loss application years, only some of the assets in the appellant's Maritime operations were sold; the appellant continued to seek- out and to bid on tenders for its marine construction operations in the Maritimes; a marine construction contract was awarded and carried out by the appellant in Newfoundland in the loss application years; marine construction contracts on which bids were made could have been executed in the Maritimes, either with the appellant's marine equipment already located in Halifax or with equipment transported from the company's Great Lakes & St. ...

The Queen, 83 DTC 5001, [1982] CTC 418 (FCTD), rev'd 84 DTC 6489, [1984] CTC 519 (FCA) Addy, J:—The applicants brought a motion before The Honourable Mr Justice Dube, the purpose of which was expressed to be: to fix a date and a place for the determination of the question whether the Petitioners (Applicants) have a solicitor-client privilege in respect of documents, books, records nd other written things seized on 8 July 1982, at the premises of Verchere, Noel & Eddy, lawyers, and kept under seal since that time by Jacques Morel, assistant sheriff for the district of Montreal: The appointment was granted but, although it was the intention of the applicants to file a formal motion for the requested relief with the usual affidavits in support for presentation at the time and place appointed, this additional step was overlooked as counsel for the parties had been attempting to settle the various questions raised. ...

Before the case of Irrigation Industries Ltd (supra), the Supreme Court in the matter of Sutton Lumber & Trading Co Ltd v MNR, [1953] 2 S.C.R. 77; [1953] CTC 237; 53 DTC 1158, had applied the test of the course of conduct. ...

As noted above, the question in this case is solely one of credibility — are the statements of Mr Bassani with respect to his intentions at the time of purchase to be believed. ...

In the event that any partner ("withdrawing partner") wishes to withdraw from the partnership or reduce his partnership interest and concurrently therewith a person ("new partner") wishes to become a member of the partnership to the extent of the reduction amount (as defined below) the withdrawing partner may give to the partnership 30 days' notice in writing ("notice") (which may be waived by all the partners) stipulating the amount by which the withdrawing partner wishes to reduce his partnership interest which amount may be the whole of his partnership Interest (” reduction amount”) and stipulating the identity of the proposed new partner. ...

See S & S Properties Ltd v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294, Hans Reicher v Her Majesty the Queen, [1975] CTC 659; 76 DTC 6001, and MNR v Joichi G Kato et al, [1969] CTC 492; 69 DTC 5308. ...

The Federal Court of Appeal in The Queen v Marsh & McLennan Limited, [1983] CTC 231 at 239; 83 DTC 5180 at 5187, after referring to statements such as that in the Anderson Logging Company case said that: “While this factor is one to be taken into account in a private company in a given case, it cannot of itself be decisive except in the absence of other relevant considerations”. ...

On January 21, 1977, a settlement was reached for a total price of $54,064.50, of which each one-eighth partner in Circle Ten was entitled to $3,379 (" expropriation one”). ...