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Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221 THURLOW, J. ... C.R. 234 at 241; [1961] C.T.C. 45 at 53. 9 + Vide Lord Macmillan in Stag Line Ltd. v. Foscolo, Mango & Co., [1982] A.C. 328 at 350. 10 [1963] S.C.R. 131; [1963] C.T.C. 51. 11 * The problem is described as follows in a note by Arnold D. ...

O’reilly & Belanger, Limited v. Minister of National Revenue, [1917-27] CTC 332, [1920-1940] DTC 121 AUDETTE, J. ... & of sec. 3 of the Act which reads as follows: "" (8) In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of:— "(a) disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income. ” These provisions of the statute, like those of the English Act. do not affirmatively state what disbursements and expenses may, be deducted, and there is in words no deductions allowed at ail unless indirectly. ... This argument, he says, would require the words *‘ wholly and exclusively’’ to read "’wholly, exclusively and necessarily”: that is the very wording of the Canadian Statute. ...

Alpine Drywall & Decorating Ltd. v. Minister of National Revenue, [1966] CTC 359, 66 DTC 5263 CATTANACH, J. ... Alpine Drywall & Decorating Ltd. v. M.N.R., [1966] C.T.C. 359; Vineland Quarries & Crushed Stone Ltd. v. ... In view of the conclusion I reached in Vineland Quarries & Crushed Stone Limited v. ...

Jacob Mayer & Sons Ltd. v. Minister of National Revenue, [1954] CTC 141, 54 DTC 1075 THORSON, P. ... Mayer & Sons. The business was entirely his and he owned all its assets. ... Mayer & Sons. A meeting of the directors followed immediately afterwards. ...

Joseph Simard & Cie, Ltee v. Minister of National Revenue, [1964] CTC 461, 64 DTC 5289 DUMOULIN, J. ... Simard & Cie Ltée, était une compagnie personnelle, l’entière propriété de Joseph Simard. ... André Piché, secrétaire de Foils Investment, en 1955 et antérieurement, spécifie que cette compagnie ‘‘.. est une ‘holding’ qui détient toutes les actions de Dominion Foils et que ne détient que ça dans son actif. ...

Campeau & Michael Petritz v. Minister of National Revenue, [1970] CTC 306, 70 DTC 6223 GIBSON, J. ... The relevant facts are as follows: The appellant Campeau was employed by and owned shares in two incorporated companies named Depco Metal Products Limited (herein called “Depco”) and Hercules Tool & Die Limited (herein called “Hercules”) and the appellant Petritz was employed by and owned shares in one only of the said incorporated companies, namely, Depco. ... London & West Riding Investments, Lid., [1967] 1 All E.R. 518 at 528; Littlewoods Mail Order Stores Ltd. v. ...

Shortt & Audrey Quinn v. M.N.R., [1960] CTC 78, 60 DTC 1056 THURLOW, J. ... Shortt, and the issue on which each case turns is whether or not the appellant is liable to pay the four per cent investment income surtax on the profits to which he or she was entitled of a business carried on under the name and style of James McTamney & Company. ... It is, I think, important to observe that, while the James McTamney & Company business was, by the will, vested in Maurice J. ...

The International Iron & Metal Co. Limited v. Minister of National Revenue, [1969] CTC 668, 69 DTC 5445 GIBSON, J. ... The voting shares of Burland Realty & Equipment Company Limited were held by the above group of persons and by one Sorie Rosenblatt. ... Goldblatt and Reuben Levy; that Burland Realty & Equipment Company Limited was controlled by the group of persons above set out in the respondent’s assumption and by Sorie Rosenblatt; and that as a consequence the appellant and Burland Realty & Equipment Company Limited were not associated corporations within the meaning of Section 39(4)* [2] of the Income Tax Act for the said taxation years. ...

Floor & Wall Covering Distributors Limited and Vina-Rug (Canada) Limited v. ... The owners and the number of shares of all the outstanding common shares (and there were no other voting shares issued in any of these companies) at all material times of each appellant company and of these two other companies were as follows: Floor & Wall Covering Distributors Limited J. ...

Pooler & Co. Ltd., 62 DTC 1321, [1962] CTC 527 (Ex. Ct.) THURLOW, J. ... Pooler & Co. Limited) of accounts in the name of C. J. Butler, Joseph Beaudry and E. ... Alexander von Glehn & Co. Ltd., 12 T.C. 232, and Imperial Oil Ltd. v. ...