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Thorson, Président de cette Cour, décrit ainsi la position des parties dans les causes en appel des décisions de la Commission d’Appel de l’Impôt sur le Revenu (p. 207, in fine): “... ...

’?’’ The test is not always easy to apply, for there is no single criterion by which the question may be resolved, and cases frequently arise in which there are circumstances or facts pointing to both conclusions. ...

It is quite true that they preferred not to sell them if a sale could be avoided, but the statement in para. 11 of the case is quite plain, that ‘ the possibility of the sale of the foreign patents or rights has always been contemplated by the appellant company in respect of such interest as it possessed in the foreign patents.’ ...

Selon ces articles lorsqu’un contribuable a signifié un avis d’opposition à une cotisation, prévu 2‘1 l’article 58, il peut interjeter un appel contre la cotisation 2‘1 la Commission d’appel de l’impôt ou 2‘1 cette Cour en suivant les conditions prescrites par l’article 59, c’est-à-dire ‘ (a) après que le Ministre a ratifié la cotisation ou procédé 2‘1 une nouvelle cotisation, ou (b) après l’expiration des cent quatre-vingt jours qui suivent la signification de l’avis d’opposition sans que le Ministre ait notifié au contribuable le fait qu’il a annulé ou ratifié la cotisation ou procédé 2‘1 une nouvelle cotisation.” ...

The appellant upon hearing of his transfer back to Minneapolis contacted, in July 1957, a firm of real estate agents in Toronto, Key & Penn, and told them to try to sell his house. ...

On April 25, 1958 the city replied enclosing a ‘c of the decision of the Technical Planning Board stating that the request to operate a feed lot on the premises was considered and refused because the property had been classified on the interim zoning guide as ‘‘ Agricultural future residential’’ which did not permit the development of feed lots and that feed lots were only permitted in heavy industrial areas under special The appeal procedure from such refusal was explained but no appeal was launched because, as Harry Sheftel testified, hé considered an appeal to be futile having been so informed by a civic official who also indicated to Harry Sheftel that he would vigorously oppose such an appeal. conditions. ...

Ross & Sons Limited, which came into existence when the partnership was dissolved and which in the years 1956, 1957 and 1959 was active in the building of houses for resale. ...

Cammel Laird & Co. (1942), L.J.R. 406, it is pointed out that the refusal to disclose is sometimes based on the fact that the information is of a type which, on the broad rule of public policy and convenience, should be kept secret and that it is at other times based on the fact that it belongs to a class of information which should not be revealed. ...

DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT   ...

’?’’ The test is not always easy to apply, for there is no single criterion by which the question may be resolved, and cases frequently arise in which there are circumstances or facts pointing to both conclusions. ...