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Canada and Coopers & Lybrand Ltd., 86 DTC 6243 (BCSC)-- summary under Subsection 227(9) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(9) A penalty for failure to remit employee source deductions on the due date of February 15, 1985 was not a claim provable in bankruptcy because the proposal under the Bankruptcy Act was filed on February 6, 1985. ...

Lowe & Ors. v. C.I.R. (New Zealand), [1984] BTC 3 (PC)-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) The taxpayers argued unsuccessfully that since "historic cost accounting was unfair", their profit from the sale of land inventory should be reduced to reflect inflation. ...

Deloitte & Touche Inc., 97 DTC 5538 (Sask. C.A.)-- summary under Subsection 224(1.2) Summary Under Tax Topics- Income Tax Act- Section 224- Subsection 224(1.2) A trustee of bankruptcy, in its representative capacity, was liable with respect to a demand for payment of a receivable made 40 days after the date of bankruptcy of the debtor. ...

Kelly, Douglas & Co. Ltd. v. MNR, 76 DTC 1090 (T.R.B.)-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory Supplies of stationery and special forms on hand at the end of the year were not inventory because they had no market value at all and were of no use to anyone other than the taxpayer. ...

Crown Cork & Seal Canada Inc. v. The Queen, 90 DTC 6586 (FCTD)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) The claiming by the corporation of CCA on an asset which had not yet been substantially completed was based on a misunderstanding of the kind of asset upon CCA could be taken. ...

Re Marks & Spencer Canada, Inc., 84 DTC 6037 (Nfld. S.C.)-- summary under Subsection 224(1) Summary Under Tax Topics- Income Tax Act- Section 224- Subsection 224(1) Since s. 224 is a garnishee provision that only binds or attaches the interest of the taxpayer, it does not apply to book debts that were assigned to a bank prior to the issuance of the s. 224 demand, notwithstanding that such issuance was effected prior to receipt by the taxpayer's debtor of notice from the bank of the assignment of book debts. ...

APL Oil & Gas Ltd. v. The Queen, 96 DTC 1666 (TCC)-- summary under Section 12 Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Section 12 An assessment that erroneously referred to the taxation year of the taxpayer as ending on January 2, 1987 rather than December 31, 1986 was deemed to be valid under s. 152(8) of the Income Tax Act, after a brief reference was made to s. 12 of the Interpretation Act. ...

Customs & Excise Commissioners v. Automobile Association, [1974] 1 WLR 1447 (HL)-- summary under Supply Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Supply Upon paying for membership in the Automobile Association, a member was considered to be paying not for the mere privilege of membership but for the benefits that a member received under his contract with the Automobile Association and, accordingly, the subscription price is apportionable among those services and facilities received by each member. ...

Smith, Kline & French Laboratories Ltd. v. A.G. Can. (1987), 12 F.T.R. 81-- summary under Interpretation Bulletins, etc. ...

Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. ...