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In that case the Court considered actions taken by a creditor to realize on security which it held for payment of a note and debenture which were payable on demand. ...

Perhaps no real comparisons could be made by Mr Jackson because of the lack of sales which he considered acceptable. ...

In Harlequin Enterprises Limited v The Queen, [1977] CTC 208; 77 DTC 5164, the Federal Court of Appeal considered whether the appellant, a book publisher, was entitled to deduct an amount intended to provide for the post year end return of books which it had sold on the basis that they were returnable for full credit. ...

Whereas it is obvious, and even admitted by the respondent that the $687.50 is over the regular interest, (ie other than an amount paid “under the terms of the bond”) the Court concludes that it must be considered as a “cash bonus” and the appeal must be allowed. 5. ...

And, most assuredly, I am unable to determine from the information and evidence presented, in what manner the amounts at issue (which formed part of a total of some $465,500) could ever have been considered as “income” to the taxpayer, Lou Lokash Limited. ...

Various attacks on the assessments were made by the appellants, but in my view the appeals can properly be decided when the two following questions are considered: (a) Did the appellant, John Rosenfeld, realize any gain? ...

Therefore it was considered that the interest paid on the borrowing of funds was for the purpose of maintaining the investments and maximizing of the income from them and therefore is properly deductible. ...

Because of the judgments which were given that day, it is considered best to write short reasons. ...

During subsequent years, certain reproduction equipment was added or exchanged, such as two sound columns, some amplifiers and microphones about which information was also provided by Mr Caron; these additions were considered in the capital reconciliation and the appropriate depreciation was calculated. ...

It is submitted that: (a) the practice of appraising real estate is a profession; (b) in order to carry out his duties as Chief Appraiser, it is necessary for the Appellant to maintain the professional status of a real estate appraiser; (c) in order to maintain a professional status in the field of real estate appraisal, it is necessary to belong to some association of real estate appraisers; (d) there are several associations available to real estate appraisers in Canada, e.g. the Appraisal Institute of Canada, The American Institute of Real Estate Appraisers, Corporation of Chartered Appraisers, the Royal Institution of Chartered Surveyors; (e) to be considered a professional appraiser in any practical sense, it is necessary to belong to one or more of the above or similar organizations; (f) the Appraisal Institute of Canada, being the only national professional appraisal organization, is the most logical one in which to maintain membership; (g) the profession of real estate appraising is recognized by statute in several jurisdictions, eg (i) in the Province of Quebec by the Professional Code, R.S.Q. ...