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.: — We are all of the view that this appeal cannot succeed. We think that the learned Tax Court judge dealt properly with the issues raised and we substantially agree with her reasons. ...

Canada (Employment & Immigration Commission), [1991] 2 S.C.R. 22, 81 D.L.R. (4th) 358, Cuddy Chicks Ltd. v. ...

.: — The motions judge allowed an extension of time for appealing a decision of the Tax Court under subsection 167(4) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

.: — The attached reasons delivered in Sokolowska v. R. (Doc. A-633-95) also constitute the reasons of the Court in this appeal. ...

’) for the 1987 taxation year on the basis that certain loans in the amount of $7,224,048.33 made by County Investments Ltd. ...

See The King v Hooper, [1942] Ex CR 193; Galway v MNR, [1974] FC 600, [1974] CTC 454; 74 DTC 6355; Northrop Corp v The Queen et al, [1977] 1 FC 289; The Clarkson Company Limited & Rapid Data Systems & Equipment Limited v The Queen, No A-884-77, Judgment of the Federal Court of Appeal September 11,1978, [1979] CTC 96. ... Counsel for the Crown invokes the provisions of the Interpretation Act, RSC c 1-23 respecting the meaning of “may” and “shall”, the decision of the Privy Council in McHugh v Union Bank, [1913] AC 299 respecting the effect of such provisions on the application of the principle affirmed in Julius v Lord Bishop of Oxford, and the reliance on McHugh by the Supreme Court of Canada in Smith & Rhuland Limited v The Queen Ex Rel Brice Andrews et al, [1953] 2 S.C.R. 95. ... In Smith & Rhuland the majority of the Supreme Court of Canada held that notwithstanding the prescribed conditions for certification the word “may” made the power to certify a discretionary one. ...

The values of these parcels of land excluding the cost of sewage pumping stations ranged from $28,930/acre to $42,365/acre with an average of $35,647/acre. [...] ... Since I have determined that the total commercial portion of the property is 86,800 square feet, its total value at $12 per square foot is $1,041,600. [...] 1 have not considered as a separate item the cost to complete the sewer line to the subject property, calculated by Mr. ... C.A.), at 687. 5 /?. v. Eastern Trust Co. (1944), [1945] 4 D.L.R. 563 (Can. ...

The appeal from the trial judgment in that case (Appeal Division # A-347-80) was argued together with this appeal. ... (emphasis added) Appellant’s counsel contrasted the use of the words “carried on” in this Subsection with the words “from a source, in Canada... ” used in subparagraph 129(4)(a)(iii). ... There are, thus, various sources of income for such corporations but income derived from an active business is excluded — a situation diametrically opposite to that encompassed by section 125. ...

., M & B Trading and Congregation Oir Hachaim set out in the statements required under (1); 3. The relationship which exists between Traitement d'Aluminium Montreal Inc. and Carroll Alloys and Metal Inc., Chicago, Illinois and M & B Trading, New York, New York as well as with their principal shareholders Nathan and Lea Muller, and Chaim Landau respectively; 4. The reasons in regards to payments from Carroll Alloys and Metals Inc. and M & B Trading to Traitement d’Aluminium Montreal Inc. ...

To this evidence must be added the facts of an appeal instituted by a certain André Côté from an assessment for the 1985 taxation year in which the Minister added $6,110 to his income, an amount which had been indicated on a T4 supplementary slip produced by Dunn & Benoît. ... In the two situations of Côté and Barbeau, the income of those appellants had been increased in the assessments based on the information indicated on the T4 slips provided by the shareholders of Dunn & Benoît, and the Minister conceded in the consents to judgment that that information was false. and went on, at pages 15 to 16: What happened to the amounts recorded on the T4 slips prepared by Benoît for the employees Côté and Barbeau and which were in addition to those admitted in the consents to judgment? ... A judge simply does not have any ex officio knowledge of what he learned in another case (see Sopinka, Lederman & Bryant, The Law of Evidence in Canada, Butterworths, Toronto, 1992, page 985) and he is failing greatly in his duty of neutrality if he makes use of such knowledge (see Ducharme, Précis de la preuve, 3d ed., Wilson and Lafleur, Montréal, 1986, page 17). ...