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Rouleau, J. stated: "I have no difficulty with the proposition that income tax interpretation bulletins may be consulted... but these materials are not binding on Her Majesty and should be considered only as persuasive authority. ...

The Queen, 85 DTC 5004, [1984] CTC 661 (FCTD)-- summary under Provincial Law Summary Under Tax Topics- Statutory Interpretation- Provincial Law It was found that since income tax law "must be interpreted consistently throughout Canada", the conferral of a benefit by deed of sale should not be regarded as a gift for the purpose of s. 69(1)(c) of the Act even though it would probably be considered as a gift in Quebec law. ...

General Provisions Although a lump sum received by the taxpayer might be considered to come within the more general terms of "remuneration" under s. 6(3)(b) in addition to constituting a retiring allowance, the rule generalia specialibus non derogant was applied to find that a retiring allowance should not be included in remuneration under s. 6(3)(b). ...

[A]ctivities may be contracted out by the taxpayer [as was the case here] and the latter will still be considered as engaging in a farming operation. ...

" It was further stated that the activities of the taxpayer would be considered by the general public to constitute "farming. ...

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. ...

., 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, 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). ...