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Coopers & Lybrand Limited and Her Majesty the Queen, [1995] 2 CTC 506 Halvorson J. ... Ja-Sha Trucking & Leasing Ltd., [1992] 2 C.T.C. 139, 89 D.L.R. (4th) 405 (Man. ... " Paragraph 435(2)(a) "... vests in the bank... all the right and title to the warehouse receipt or bill of lading and to the goods.... ...

Minister of National Health & Welfare, [1989] 2 CTC 122 Mahoney, J.A. ... We here have a hospital, in which as a building, hospital accommodation is provided for all in that part of the (Min. of National Health & Welfare) country who are able, to the extent of such accommodation, to take advantage of it. ... (Min. of National Health & Welfare) The appellant relied heavily on Struthers v. ...

Joe’s & Company Ltd. v. Minister of National Revenue, [1986] 1 CTC 2123, 86 DTC 1073 Sarchuk, T.C.J.:—Joe's & Company Ltd. (Joe's) appeals from assessments to tax with respect to its 1974 and 1975 taxation years. ... More specifically: (i) 1377- 1385 Winnipeg Avenue — this property was acquired in 1971 and was first listed for sale on April 19, 1972. ...

Andrew Paving & Engineering Ltd, Meld Development LTD v. Minister of National Revenue, [1984] CTC 2164, 84 DTC 1157 Christie, CJTC:—The issues on these appeals are the same. ... Land & Tbr. Co. v. Watkins, [1904] 1 Ch. 242. On the other hand and in contrast, where the sole duty of the agent with respect to the money is to pay it to his principal, the relationship between the parties is that of debtor and creditor: Friend v. ... Included in the amounts in respect of which late remittance penalties and interest were assessed was $9,214.17 (Andrew Paving & Engineering Ltd) and $8,853.04 (Meld Development Ltd). ...

Hope Hardware & Building Supply Co. Ltd. v. Minister of National Revenue, [1967] CTC 120, 67 DTC 5085 SHEPPARD, D.J. ... That resulted in the agreement (Ex, 49) of December 9, 1959, between the Hope Hardware & Building Supply Co. ... This appellant, Hope Hardware & Building Supply Co. Ltd., contends that the timber sales in question were bought for the use of the partnership to be logged in future and not for the purpose of resale; that the timber licences were a capital asset, and that the sale to Pretty’s Limited was a sale of the business and not a sale in the course of the business and therefore not taxable. ...

Nomad Sand & Gravel LTD v. Minister of National Revenue, [1982] CTC 2035, 82 DTC 1070 The Chairman:—The appeal of Nomad Sand & Gravel Ltd is from assessments with respect to the 1974, 1975, 1976 and 1977 taxation years. ... The appellants, pursuant to Regulation 1201, also sought to deduct / of their profit from the business by claiming that gravel was a mineral resource. The Minister disallowed both the 50% capital cost depreciation and the deduction of / of the appellants’ profit under Regulation 1201. ...

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA). ... Willson, the chartered accountant with the firm of Clarkson Gordon (now Ernst & Young), who was responsible for auditing the plaintiff's books. ... There was some suggestion in the presentation of this case that the concept ” reserve for doubtful debts" found in paragraph 20(1)(l) of the Act is different from the concept ” reserve for doubtful accounts" used in the preparation of financial statements, because the terminology in which each is expressed differs. ...

Marsh & McLennan, Ltd., 83 DTC 5180, [1983] CTC 231 (FCA) Clement, D J:—At issue in this appeal is whether interest income received by Marsh & McLennan Ltd (the broker) from short-term investments in its 1976 taxation year was “Canadian investment income” within the definitions of paragraph 129(4)(a) of the Income Tax Act. ... By an “endorsement” of the same date it was agreed that Marsh & McLennan, Limited should be called “Broker” instead of “Agent” in the contract. ... It was deposed that each of such investments, when made, would take 15 to 20 minutes of the time of the manager — a very small part of the time of his working month. ...

Block Research & Development (1981) Corp. v. MNR, 87 DTC 5137, [1987] 1 CTC 253 (FCTD) Dubé, J. ...

Luigi Tiengo Art & Design Inc. v. Minister of National Revenue, [1992] 1 CTC 2097, 91 DTC 1216 Lamarre Proulx, T.C.C.J. ...