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Sie-Mac Pipeline Contractors Ltd. v. M.N.R.

[1993] 1 SCR 895 Court SCC Decision date 1993-03-24 Docket 22775 English

PartiesSie‑Mac Pipeline Contractors Ltd. Appellant·Her Majesty The Queen Respondent

Judges La Forest, Gérard V.; Gonthier, Charles Doherty; Cory, Peter deCarteret; Iacobucci, Frank; Major, John C.

Decision 4–1 Majority (4) · Iacobucci J. (1)

On appeal from Federal Court of Appeal

Subjects Taxation

Contents

Majority

The judgment of the Court was delivered orally by

Iacobucci J.

Iacobucci J. ‑‑ We are all of the view that this appeal should be dismissed for the reasons given by Mr. Justice Linden of the Federal Court of Appeal. The expenses in question are clearly precluded by the provisions of s. 18(1)(l)(i) of the Income Tax Act.
Accordingly, the appeal is dismissed.
Under the circumstances, the appellant should have its costs in the courts below; there will be no order as to costs in this Court.
Judgment accordingly.
Solicitors for the appellant: Felesky Flynn, Edmonton.
Solicitor for the respondent: John C. Tait, Ottawa.

Statutes and regulations cited