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Nomad Sand & Gravel Ltd., 87 DTC 5343, [1987] 2 CTC 112 (FCTD)-- summary under Class 22 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 22 A sand and gravel pit was not a "mine", and front end loaders used in the gravel pit operation accordingly were Class 22, rather than Class 10 assets. ...

Firestone Tyre & Rubber Co. Ltd. v. Lewellin (1957), 37 TC 111 (HL)-- summary under Agency Summary Under Tax Topics- Income Tax Act- Section 9- Agency- Agency The Court affirmed a finding that sales by the taxpayer, which was a U.K. special-purpose manufacturing subsidiary of a U.S. corporation, were made by it as agent for the U.S. corporation. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Subsection 152(8) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(8) incorrect year referenced An assessment that erroneously referred to the taxation year of the taxpayers ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8). ...

& J. Music Ltd., 80 DTC 6219, [1980] CTC 287 (FCTD)-- summary under Subsection 165(1) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(1) A taxpayer was not entitled to appeal from a determination of its cumulative deduction account where the amount of tax for the year was not affected. ...

John Shipbuilding & Dry Dock Co. Ltd., 80 DTC 6272, [1980] CTC 352 (FCA)-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) In obiter dicta it was suggested that lump-sum payments for a non-exclusive licence to use computer programs in the design of ships were covered by s. 106(1)(d)(i) of the pre-1972 Act. ...

Goar, Allison & Associates Inc. v. The Queen, 2009 DTC 653, 2009 TCC 174 (Informal Procedure)-- summary under Subsection 162(2.1) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(2.1) The taxpayer would not have been liable for a penalty under s. 162(1) because it had no income. ...

Smith, Kline & French Laboratories Ltd. v. A.G. (Can.), 89 DTC 5205, [1989] 2 CTC 63 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus There is a common law presumption in support of public access to the courts and court records, and the burden of persuading the court that access should not be provided is upon the person who seeks to deny it. ...

Canadian & Foreign Securities Co. Ltd. v. MNR, 72 DTC 6354, [1972] CTC 391 (FCTD)-- summary under Paragraph 108(2)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(b) Demand loans made to a company which were evidenced by unsecured promissory notes were found to be "securities" for purposes of the definition of "investment company" in s. 69(2) of the pre-1972 Act. ...

Patons & Baldwins Ltd. v. MNR, 69 DTC 189, [1969] Tax A.B.C. 221-- summary under Subsection 147.2(1) Summary Under Tax Topics- Income Tax Act- Section 147.2- Subsection 147.2(1) S.11(1)(g) of the pre-1972 Act was found to preclude the deduction of annual contributions to an unregistered pension plan under the general law relating to deductions by commercial enterprises. ...

Will-Kare Paving & Contracting Ltd. v. Canada, 2000 DTC 6467, 2000 SCC 36, [2000] 1 S.C.R. 915 (SCC)-- summary under Hansard, explanatory notes, etc. ...