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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. ...

As it was not clear what the result of an independent review would have been, the matter was referred back to be considered by a different CRA adjudicator. ...

As it was not clear what the result of an independent review would have been, the matter was referred back to be considered by a different CRA adjudicator. ...

This would, however, imply a very marked divergence from what is considered normal. ...

"12(1)(b), it was thought necessary, or at least desirable, to make it clear that the word 'receivable' was to include sums which would not, in ordinary language, be considered to be receivable within the particular taxation year". ...

.)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) demand note not bona fide repayment arrangement Te defendant was found to be negligent in not advising of the risk that the signing by the individual plaintiff of a demand promissory note as security for a housing loan made to her would not be considered to represent a bona fide arrangement for repayment of the loan within a reasonable time. ...

., 78 DTC 6510, [1978] CTC 636 (FCTD)-- summary under Comparison of Provisions Summary Under Tax Topics- Statutory Interpretation- Comparison of Provisions "Words used more than once in a statute may not always have the same meaning, but they are normally considered to have the same meaning unless the context shows they are being used in a different sense. ...

The Queen, 78 DTC 6103, [1978] CTC 44 (FCTD)-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business In order for an undertaking to be considered a "business" it must be carried on with a reasonable expectation of profit. ...

The Queen, 96 DTC 1196, [1995] 1 CTC 2647 (TCC)-- summary under Paragraph 96(2.4)(a) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.4)- Paragraph 96(2.4)(a) The taxpayer was not a limited partner of a partnership governed by Ontario law given that the partnership had not been registered under the Limited Partnerships Act (Ontario) in the relevant taxation years, and given that the taxpayer exercised such a degree of control in the operations that he could not be considered a limited partner even if the partnership had been so registered. ...

The Queen, 88 DTC 6352 (FCA)-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no reserve if s. 9 inclusion S 20(1)(m) only provides a reserve in respect of amounts which would be considered to be unearned in the absence of s. 12(1)(a). ...