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Before reaching this conclusion, Joyal J. stated (p. 6282) that: "... although a profit, expressed in percentage terms as a return on investment, on energy and time and effort expended, might not be of a nature to invite a take-over bid..., the test of reasonableness is met if a profit has been realized. ...

Before reaching this conclusion, Joyal J. stated (p. 6282) that: "... although a profit, expressed in percentage terms as a return on investment, on energy and time and effort expended, might not be of a nature to invite a take-over bid..., the test of reasonableness is met if a profit has been realized. ...

With respect to the initial character of each overriding commissions as income when receivable, Brandeis J. stated (p. 199): "... the mere fact that some portion of it might have to be refunded in some future year in the event of cancellation or reinsurance did not affect its quality as income... ...

., the taxpayer disposed of "a right to a right" of the sort described in what then was s. 66(15)(c)(ii)(B) when under a "farmout agreement" with Esso Resources Canada Limited, the taxpayer received from Esso the sum of $4.5 million in consideration for "... the right, licence and privilege of earning an interest in oil sands rights... ...

See summary under s. 12(11) – investment contract. ...

See summary under s. 12(11) – investment contract. ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

See summaries under s. 232(1) – solicitor-client privilege and Tax Court Rule 82(2). ...

Especially must this be so where the chattels being considered are subject to wear and tear through use … In my opinion the word “permanent”, as used by King J. should be interpreted for the purposes of this appeal as indicating the object of having the carpeting remain where it is so long as it serves its purpose. ...