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PHILLIPS & VINEBERG Per: Philip. F Vineberg, Solicitor for the Appellant DATED AT MONTREAL, this 17th day of November 1977. ... In the words of Thurlow, J in McMahon v MNR, [1959] CTC 166 at 171; 59 DTC 1109 at 1111: “... ...

One statement to this effect is found in the judgment of Thurlow, J, as he then was, in the Court of Appeal in the case of MNR v Yonge- Eglinton Building Limited, [1974] FC 637 at 653; [1974] CTC 209 at 219;* 74 DTC 6180 at 6187, where he states: Principal Interest Total Total (a) November 28th, 1968 660,000.00 — 660,000.00 (b) July 20th, 1969 311,169.00 14,031.19 325,200.19 (c) August 25th, 1970 233,101.00 28,431.74 261,532.74 (d) October 4th, 1971 597,377.00 119,262.60 716,639.60 $1,801,647.00 $161,725.53 $1,963,372.53 No witnesses were called.... ... Reference was also made to the case of Raja’s Commercial College v Gian Singh & Co Ltd, [1977] AC 312, in which the Simpson v Executors of Bonner Maurice and Riches v Westminster Bank Ltd cases (supra) were discussed in detail. ...

The Minister assessed the company to sales tax on the basis that the processed marble constituted “goods produced or manufactured in Canada” under paragraph 30(1)(a) of the Excise Tax Act, RSC 1952, ¢ 100. ... It was stated in this way by Parke, B (Becke v Smith (1836), 2 M & W 191 at p 195): “it is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used, and to the grammatical construction, unless that is at variance with the intention of the legislature, to be collected from the statute itself... ...

In Cornwall v Ottawa & New York Railway (1915), 52 SCR 466, Chief Justice Duff held: It is a long settled rule that a given subject is not to be held to be a subject of taxation unless the intention to include it among the subjects of taxation is expressed in “clear and unambiguous language’’. ... The option was exercised and a P & NG Lease dated December 20, 1947, was granted by Hamula to Naylor and Michelberry. ...

In 1953 he purchased the assets owned by the 1935 company from the estates of the then deceased original partners and shareholders and incorporated a new company under the name of McCallum Hill & Co Limited (hereinafter referred to as McCailum Hill) to continue the business of the former company. ... Prior to this event Mr Hill had commissioned Larry Smith & Co of Seattle, Washington, a firm of real estate consultants who also describe themselves as economic consultants, to prepare a brochure of the proposed shopping centre including a site plan of the centre showing the location and description of retail outlets and a drawing of the centre, both prepared by H K Black, an architect in Regina engaged by Mr Hill to do this, a plan of the development the same as the general Outline Plan approved by the City Council on December 23, 1957, which was a year subsequent to the completion of the brochure in December 1956, to demonstrate the accessability of the site, a review of the trade area to be served, the income and buying power of the residents of that area, the sales potential and the prospect of increase therein and a comparison of the Hillsdale site with competing sites. ...

It further maintains that the building should be classed in Class 3, and the lessee rights in Class 13, by virtue of the decision in Cohen & Zalkind v MNR, [1967] CTC 254; 67 DTC 5175. ... One of these letters (similar to those written to other tenants) was sent to Messrs Paquette & Paquette, one of the tenants, and reads as follows: Dear Sirs: Since acquisition of the Transportation Building by our subsidiary company, some tenants have inquired with some concern as to our plans for this building. ...

Working to earn, in the plaintiff’s philosophy, builds character, self-discipline, moral strength, perseverance and self-confidence — a commendable objective. ... If he guarantees nothing he cannot be found liable as a guarantor — a simply straightforward solution. ... Both Claude and Pauline Bouchard testified as to facts concerning the transaction which are compatible with the creation of a trust with themselves as beneficiaries and the plaintiff and his wife as the nominal owners, holding the title to the property as trustees for their benefit — all the essential elements of a trust. ...

London & W. Riding Invest. Ltd., [1967] 1 All E.R. 518 at pages 528-29: As regards the contention of the plaintiff that the transactions between himself, Auto-Finance, Ltd. and the defendants were a "sham", it is, I think, necessary to consider what, if any, legal concept is involved in the use of this popular and pejorative word. ... A clear exposition of the idea is found in The Principles of Income Taxation by Hannan and Farnsworth (London, 1952, Stevens & Sons Limited). ... Attorney-General (1869), 4 E & I App. 100 at page 122, and Lord Halsbury in Tennant v. ...

He was carrying on his business under the name of Ken Allen & Sons Limited and was apparently the sole shareholder save for qualifying shares. ... Other certificates were also registered against Ken Allen & Sons Limited. ... Horses were entered in the show under the name Ken Allen and Sons — owner. ...

.: — This is an appeal from the judgment of the Honourable Mr. Justice Steele, sitting in Weekly Court, dated January 12, 1987, wherein he ordered Giuseppe Vettese to attend for cross-examination on affidavits sworn in support of four search warrants issued pursuant to section 231.3 of the Income Tax Act, S.C. 1970-71-72, c. 63, as amended by S.C. 1986, c. 6 (herein the "Income Tax Act"). ...