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FCA
Prince Rupert Hotel (1957) Ltd. v. The Queen, 95 DTC 5227, [1995] 2 CTC 212 (FCA)
., as he then was, in London & Thames Haven Oil Wharves Ltd. v. Attwool (1966), 43 T.C. 491, at page 515: The question whether a sum of money received by a trader ought to be taken into account in computing the profits of gains arising in any year from his trade is one which ought to be susceptible of solution by applying rational criteria. ...
FCA
Bellingham v. The Queen, 96 DTC 6075, [1996] 1 CTC 187 (FCA)
The precise scope of the residual category- windfall gains — has proven problematic. ...
FCTD
Pacific Northern Gas Ltd. v. The Queen, 90 DTC 6252, [1990] 1 CTC 380 (FCTD), aff'd 91 DTC 5287 (FCA)
The Queen, [...] that argument cannot be rejected. Indeed, in that decision, as I read it, the Court held that the word "distribution" in Class 2 is used in a very general sense that encompasses what the jargon of the natural gas industry refers to as the transmission and the distribution of gas. ...
FCTD
Interprovincial Co-operative Ltd. v. The Queen, 87 DTC 5115, [1987] 1 CTC 222 (FCTD)
Squibb & Sons Ltd. v. M.N.R., [1973] F.C. 162; [1973] C.T.C. 120, The Queen v. ...
FCA
Augart v. The Queen, 93 DTC 5205, [1993] 2 CTC 34 (FCA)
., supra, at page 2278 (D.T.C. 271) (T.C.C.) where Bonner, T.C.C.J. stated: In my view the definition of “ principal residence" contained in paragraph 54(g) is such that considerations as to what can lawfully and effectively be conveyed are irrelevant. ...
FCA
The Queen v. United Equities Ltd., 95 DTC 5042, [1995] 1 CTC 164 (FCA)
Minister of Manpower & Immigration, [1978] 2 S.C.R. 375, 81 D.L.R. (3d) 687, at page 381 (D.L.R. 691). ...
TCC
Leigh v. The Queen, docket 96-2818-IT-G
Therefore, the maximum amount that could be assessed against the Appellant was $20,912 calculated as follows: Amount assessed under section 160 $52,662.30 Estimated value of the Appellant's shares according to evidence between $58,000 to $69,000 say $63,500.00 One-half thereof to Mrs. ...
TCC
Legal v. M.N.R., docket 98-954-UI
In 1994- according to Records of Employment – Exhibits R-4 and R-5- she worked 14 weeks for Doreen McMillan and 8 and 2/3 weeks for Almey. ...
TCC
Nova Corp. Of Alberta v. R., [1996] 1 CTC 2164, 95 DTC 599
At page 87 of his text Construction of Statutes (2nd ed. 1983), Driedger fittingly summarizes the basic principles: “... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”. ...
TCC
Robert Kondrat v. Her Majesty the Queen, [1995] 1 CTC 2630, 96 DTC 1566
David Pilkington, a chartered accountant and partner of Hudson & Company, Karon’s accountants, prepared a letter for Kondrat’s solicitor suggesting the shares of Karon in June 1985 "would be worth a value anywhere from $0 indicating the seismic data was worthless and the future earnings potential of the company is not very favourable to a value far exceeding the cost of the seismic data indicating that the seismic data is extremely valuable". ...