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Coopers & Lybrand Limited, supra, at page 6547, as follows: In Crown Tire, Strayer was required to construe the phrase as it is used in paragraph 125.1(3)(a) of the Act. ...

.: — This is an appeal by way of trial de novo from a decision of the Tax Court of Canada, dated April 5, 1991, which allowed the defendant’s appeal from reassessments for the taxation years 1980, 1981, 1982, 1983, 1984, and 1985. ...

En cela je suis d’accord avec le procureur des appelants qui écrit dans son mémoire: Section I — La première question qui se pose est celle de la juridiction de la division de première instance de la Cour Fédérale à supposer même que les appelants auraient raison de prétendre que le certificat (pièce P-2) constitue un faux et un abus de pouvoir d’une part et que l’article 244(4) ou bien ne s’applique pas vu la Déclaration canadienne des droits de 1960 ou doit être interprété comme limitant la portée des mots “preuve concluante” au tribunal de premiere instance devant lequel les appelants sont accusés, soit à la Cour des Sessions de la Paix. ...

At the time that the loans were made, the respondent acquired over 99 % of Copeland’s issued shares and all of Renown’s issued shares except those that already belonged to Copeland. ...

The plaintiff’s assessment for the taxation year 1966 will be referred back to the Minister for reassessment not inconsistent with these Reasons. 1 See: Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] CTC 99; 70 DTC 6085, and Pigott Investments v The Queen (supra). ...

As for the word " property", it too has been widely interpreted. ...

In deciding the main point the learned trial judge concluded (at 478; DTC 6504) that: “There were no tuition fees charged by any of the three corporations” and that “... no material consideration and no tuition fees were charged or given”. ...

Town & County Bank, 13 App. Cas. 418 at p. 424, ‘‘the profit of a trade or business is the surplus by which the receipts from the trade or business exceed the expenditure necessary for the purpose of earning those receipts’’. ...

As well, he referred to Re Canadian Cereal & Flour Mills Co., 67 D.L.R. 234 which stands for the proposition that there is nothing in the Bankruptcy Act which places a company which has made an assignment in any different position from a natural person. ...

(r) Both corporations changed their taxation year to December 30 in 1971 and the sales and net income reported have been the following for each corpora- Defendant Covertite (Ontario) Ltd Year ending Dec. 30/71 Sales $ 806,843 $501,957 Net income 39,368 22,615 Year ending Dec. 30/72 Sales $1,141,655 $577,096 Net income 31,176 21,479 (s) The combined taxable incomes of the Defendant and Covertite (Ontario) Ltd. were as follows for the taxation years ending on the indicated dates: Jan. 31/71 62,315.09 Dec. 30/72 $70,907.00 From the figures given in (m) and (n), it is clear that the defendant company was consistently adjusting its salaries and bonuses so that the net profit remained just below the amount at which a higher tax rate would have been payable, which showed the importance of tax considerations in the defendant’s and Mr Warner’s activities. ...