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Baker et al. (1975), 55 D.L.R. (3d) 224 at p. 229, [1976] 1 S.C.R. 254 at p. 261, 38 C.R.N.S. 306, where he referred to it as “the doctrine of privilege as so ably considered in Wigmore”. ...

I am further satisfied that the corporation, by reason of the foregoing, should be considered as having sold (or exchanged for parts) those vehicles with the result that the amount of $18,894 should have been included in the corporation’s gross income. ...

She considered that the earned income should not be reduced by rental losses since those losses were sustained by a company in which she was only a limited partner, and so only a passive participant not actively engaged in the business. ...

This criteria has been considered earlier in this judgment and favours the Respondent’s position. ...

Under the circumstances the Court ordered the parties to proceed with their respective argument as the Court considered that enough time had been wasted on the appeal. ...

While these added value to, and ultimately resulted in a work capable of ownership, hence property, the services themselves were not capable of ownership and therefore should not be considered property. ...

The question is which of the two sites must be considered. All the cases cited above heard by the Tax Review Board (Nelson and Viitrarc), the Tax Appeal Board (Davey) and the Federal Court (Merten) were decided in circumstances similar to those of the instant appeal, in that the employer’s establishment to which the taxpayer ordinarily reported for work was the construction site, not the employer’s principal place of business. ...

He submitted that he considered this to be a basis for reassessment by the Minister of National Revenue (“Minister”) because paragraph 6(e) of the Reply to the Notice of Appeal, setting forth “assumptions of fact” made by the Minister stated: As of May 1, 1991, the fair market value of the Northeast Quarter was for the most part dependant upon the value of the deposits of limestone contained under the surface of the property. ...

Pyke (1908), 25 T.L.R. 127, at p. 128, where it was held that there must be a certain degree of system and continuity about the loan transactions before these transactions can be considered as the carrying on of a money-lending business. ...

(C) the Restaurant had a liquor license and did deliveries; (d) the assets of the Restaurant were sold in November 1994; (e) during the years under appeal, the Appellant was married to Anna Vitti and had two dependent children; (f) the books and records of the Restaurant business for the said taxation years were not such as to permit accurate verification of the Appellant’s income for these years; [The Appellant considered the books and records satisfactory but this was contradicted by Linda Rieux, the Revenue Canada auditor. ...