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Roberge & Fils acted only as a “vehicle” for the eventual transfer to 2745-8017 Québec Inc. What is more, the hypothec held by Roberge & Fils Inc. could have been challenged, as therefore could the giving in payment. ... In a sale the extinction of the debt of the former creditor is only incidental, while in a viving in payment it i the primary result sought he ¢. ...

J Comtois & Fils Ltee v. Minister of National Revenue, [1978] CTC 3214, [1979] DTC 1 Guy Tremblay:—La présente cause fut entendue à Montréal (Québec) le 11 mai 1978. ... Ici, le cheque de la compagnie d’assurance n’a pas été fait à l’ordre de J Comtois & Fils mais à ses créanciers. ll s’appuie également sur l’opinion émise dans le Bulletin d’interprétation no 293, au paragraphe 19: 19. ... Il y est dit que l’acheteur Joseph Comtois & Fils Limitée a pris une assurance de “The Prudential Insurance Company of America” (police groupe G L-360) sur la vie d’une personne dont apparaît “sur la ligne B plus bas”. ...

Pooler & Co. Ltd., 62 DTC 1321, [1962] CTC 527 (Ex. Ct.) THURLOW, J. ... Pooler & Co. Limited) of accounts in the name of C. J. Butler, Joseph Beaudry and E. ... Alexander von Glehn & Co. Ltd., 12 T.C. 232, and Imperial Oil Ltd. v. ...

Lagueux & Freres Inc., 74 DTC 6569, [1974] CTC 687 (FCTD) Décary, J:—This appeal relates to the years 1966 and 1967, when the Minister issued an assessment under which he held that the contracts at issue are contracts of sale, not rental contracts. ... It concerns an amount of $52,134.30, for a traxcavator and a ‘‘Pulpwood” (?) ... In A R Williams Machinery & Supply Co v Morin, [1933] S.C.R. 570, Cannon, J of the Supreme Court, after reviewing the Quebec case law, Said, at page 580: This solution, adopted in several similar cases, is not binding on this Court. ...

Hanley & Company Ltd. in 1977, amounting to $146,238.00 are taxable as income, not as a capital gain as originally reported. ... Hanley & Company Ltd. in accordance with the above, thereby increasing taxable income by $73,114.00. ... But, I also conclude the Minister has raised sufficiently the issue that what occurred here was ”... an adventure... in the nature of trade... ...

& R. Asphalt Ltd. v. Minister of National Revenue, [1989] 1 CTC 2370 Sarchuk, T.CJ.:— The appellant L & R Asphalt Ltd. appeals from a reassessment of income tax for its 1985 taxation year. ... Nomad Sand & Gravel Ltd., [1987] 2 C.T.C. 112; 87 D.T.C. 5343. Counsel for the respondent argued that the Feeder does not in any reasonable fashion fit the definition of "property" set out in Class 22 of the Regulations. ... You don't use it to, say, move gravel from a pit to a location down the road, you don't hook it on to the back of the truck and — A. ...

Hadiken Concrete & Supply Ltd. v. R., [1998] 3 CTC 2777, 98 DTC 1984 Bell T.C.J.: Issue The issue in each of the appeals is whether a gain realized on disposition of an interest in a limestone quarry was on capital or income account. Facts At the commencement of his submissions, Respondent’s counsel said that if the sale by Lawrence Hadiken (“Lawrence”) was on capital account, then the sale by Hadiken Concrete & Supply Ltd. ... Concrete advertised in a number of journals as Selkirk Limestone Quarries giving its address, telephone numbers and hours of operation, including the following words FOR PICKUP & DELIVERY. ...

Great Atlantic & Pacific Tea Co., [1975] C.T.C. 432, 75 D.T.C. 5283 Collier, J: 1 The plaintiff is claiming from the defendant an “allowable refund” of $474,008.59 and certain other relief. ... The tax and interest were paid on January 22, 1973. 3 Prior to the end of its fiscal year, the plaintiff paid to its shareholders taxable dividends, as follows: June 1, 1971 $ 750,000 December 29, 1971 $2,000,000 February 24, 1972 $1,950,000---------- $4,700,000 4 Those dividends, of course, had been subject to withholding tax. ... Counsel put it this way: As in the case of cumulative taxable income, when one is calculating allowable refundable tax on hand at any particular time, one includes tax payable for taxation years other than the straddle year, only if those years have ended before the particular time; but one include, in any event, the amount specified in respect of the straddle year, whether or not it has ended before the particular time. 11 The defendant fastens on the words in subparagraph 133(9)(b)(ii) “... its [the plaintiff's]... taxable income for that year...” ...

& M. Wood Products (1985) Ltd. v. R., 98 D.T.C. 1410, [1998] 2 C.T.C. 2701 Reeve, T.O., T.C.C.: 1 This taxation of costs was heard via conference call at 12:00 PM (PST) on Friday November 7, 1997. ... & M. Wood Products (1985) Ltd. Forest Management License Agreement, transcript of John Kennedy Davies and related undertakings, and financial statements for L & M Wood Products (1985) Ltd. 18 hours Preparation of quantitative schedules from the undertakings, including Schedule of Reforestation Costs, Schedule of Road Construction, Schedule of Volumes Harvested, Schedule of Areas Harvested, and Schedule of Dues 5 hours Analysis and reconciliation of data provided regarding the Renewal Fund in the accountant's working papers, Statement of Activity, financial statements, ledger cards and bank records for 1987 to 1990 12 hours Preparation of Evidence 36 hours Review of Evidence and background documents in preparation for Trial 8 hours Time spent by Kathryn Holgate 109 hours @$130 $14,170 Partner Consultation, Review of Evidence 9.5 hours @$200 $ 1,900 $16,070 12 In the case of Quintal v. ...

Marjorie Joyce Devereux and Reiter & Rain, [1992] 2 CTC 310 Catzman, Galligan and Arbour, JJ.A.:— It is not disputed that the liability for income tax, which was ultimately discharged by the respondent, was that of the appellant. ...