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But on consideration of all the evidence, I find that it's all intertwined, and that his point, that he simply purchased a motor home and received a rebate is not supported by the review documentary evidence such as the agreement R-1. ...

Such an approach would, she submitted, violate a fundamental rule of statutory construction namely that: Not only must the whole Act be read, but every provision of the Act should, if possible, be given meaning; hence, if there are rival constructions the general principle is that the construction that gives effect to the whole of the statute, or to the provision under consideration, should be adopted in preference to one that renders part thereof meaningless. [4] In my view the position of counsel for the respondent is correct. ...

It remained a source of income and an investment property until they moved into it on November 1, 1989, While they may have considered the alternative of using it for their own residence, the application of the Income Tax Act is not based upon the vagaries of a taxpayer's consideration of alternative uses. ...

Contrary to the respondent's argument that the decision in O’Donnell supports his argument, that judgment accepts the opposite position by point ing to the need that a section such as the one under consideration must clearly and expressly set out the taxpayer's duty. ...

Referring to the same case a passage at page 399 (C.T.C. 77, D.T.C. 1051) was indicated to the Court as follows: It would be a strange result if the question, whether legal expenses incurred in enforcing and preserving a right should be regarded as an outlay on account of capital or on account of income, fell to be determined on a consideration not of the true nature of that right but of the nature of the ill- founded grounds on which it was disputed. ...

His wife could not leave her nursing position in B.C. due to pension considerations and he did not want to leave his position with the union until he could collect a full pension. ...

" Appellant's Position The appellant argues that: (A) he exercised his option as agent for others as the essence of the transaction (and not the form) was an assignment of the option for no consideration, or in the alternative, (B) on the authority of the Beament (A.W.) ...

Consideration was cash, assumption of liabilities, and a chattel mortgage for the balance. ...

On a careful reading of the relevant sections of the Act, and upon consideration of the evidence, I am satisfied that the plaintiff must succeed: the sums received by her pursuant to the lottery scheme constitute a tax- free windfall under subsection 52(4). ...

The Queen, [1986] 1 S.C.R. 264; [1986] 1 C.T.C. 410; 86 D.T.C. 6179, the Supreme Court of Canada held that payments similar to those under consideration were payments made for the taxpayer's maintenance. ...