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In 1969 it availed itself of the provisions of Income Tax Regulation 1100(1)(e) and deducted the sum of $16,875.40 pursuant to the provisions of the said Regulation and Schedule C. 7 The question to determine here is: Was this consideration for the assignment of a depreciable capital asset within the meaning of the Income Tax Act and the pertinent regulations thereto, or was this a capital outlay to acquire a preferred position to obtain timber sales licences in the future? ...

Is this not taken into consideration at all? If we look at the situation differently, that is, if we suppose that there was no joint custody and that my four children lived with me during the first 26 consecutive weeks of the year, you could not then deny the fact that they were wholly dependent on me during this period. ...

Legal costs to prosecute and to defend most tort, contract and other civil claims arising in the ordinary course of business will generally be deductible. 9 The Appellant also contends that he was forced to settle because of financial considerations. ...

Where there is inconsistency between the content of such a brochure and the text of the Act, the Act alone must be taken into consideration. 15 Furthermore, I believe it is important to note that the brochure to which the appellant referred does not support his claims. ...

The property was sold for $750,000.00 being the amount of the first mortgage on this property which 815360 Ontario Inc. assumed in consideration of the purchase price. ...

The consideration for this grant, as set out in the sublease, consisted of (a) a payment of $100,000 per year to be made to the Province of Quebec, (b) the sublessee’s share of the duties payable under the Quebec Mining Act, and (c) ‘an overriding royalty on all iron ore and specialties shipped by the Sublessee under this Sublease from any mines upon the described lands (except iron ore and specialties shipped for the account of the Sublessor) and sold and delivered each year by the Sublessee, of seven per cent of the then competitive market price f.o.b. vessels at Seven Islands, Quebec (determined as provided in Section 2 of the Mutual Covenants of this Sublease) for each grade and kind of such iron ore and specialties, which the Sublessee binds itself to pay to the Sublessor during the term hereof; provided however, that, in the event seven per cent of such competitive market price for any grade or kind of such iron ore or specialties shall be less than twenty-five cents a ton, then the overriding royalty on such iron ore and specialties shall be twenty-five cents a ton.” ...

A consideration of all the evidence and of the authorities and dictionary definitions to which we were referred, brings me to the conclusion that neither in technical terms nor in common speech nor in that of those who deal in such products would the skin of a mature merino sheep with the wool or hair attached to it be described as a fur. ...

Other considerations also militate strongly against the admission of the instant plea. ...

Under the circumstances it was contended by counsel for the appellant that the notice of cross-appeal was not given in time and that the cross-appeal was not before the Court for consideration. ...

All these considerations lead to the conclusion that the appeal to this Court from a decision of the Income Tax Appeal Board, whether by the taxpayer or by the Minister, is a trial de novo of the issues involved, that the parties are not restricted to the issues either of fact or of law that were before the Board but are free to raise whatever issues they wish even if different from those raised before the Board and that it is the duty of the Court to hear and determine such issues without regard to the proceedings before the Board and without being affected by any findings made by it.” ...