A-812-95
LINDEN, J.A.
ROBERTSON, J.A.
B E T W E E N:
ALCO DISPENSING CANADA LTD.
(PREVIOUSLY BOOTH DISPENSING LIMITED)
Appellant
-and-
HER MAJESTY THE QUEEN
Respondent
HEARD at Toronto, Ontario, Monday, June 23, 1997.
REASONS FOR JUDGMENT delivered from the Bench at Toronto, Ontario, on Monday, June 23, 1997.
REASONS FOR JUDGMENT BY: ROBERTSON, J.A.
A-812-95
LINDEN, J.A.
ROBERTSON, J.A.
B E T W E E N:
ALCO DISPENSING CANADA LTD.
(PREVIOUSLY BOOTH DISPENSING LIMITED)
Appellant
-and-
HER MAJESTY THE QUEEN
Respondent
REASONS FOR JUDGMENT
(Delivered from the Bench at Toronto, Ontario,
on Monday, June 23, 1997.)
ROBERTSON, J.A.:
Succinctly stated the issue raised on this appeal is whether Bonner J.T.C.C. erred in finding that the forgiven bonus amount of $1,589,024.00 is to be included as income under Section 9 of the Income Tax Act for the 1987 taxation year by virtue of paragraph 80(1)(f). Despite the able argument of Mr. Krishna we have not been persuaded that the learned Tax Court Judge erred and, therefore, the appeal must be dismissed with costs, substantially for the reasons offered in the judgment below.
"J.T. Robertson"
J.A.
FEDERAL COURT OF CANADA
Names of Counsel and Solicitors of Record
COURT NO: A-812-95
STYLE OF CAUSE: ALCO DISPENSING CANADA LTD. ET AL.
- and -
DATE OF HEARING: JUNE 23, 1997
PLACE OF HEARING: TORONTO, ONTARIO
REASONS FOR JUDGMENT BY: ROBERTSON, J.A.
Delivered from the Bench at Toronto, Ontario
on Monday, June 23, 1997
APPEARANCES:
Mr. Vern Krishna, Q.C.
Mr. Larry Banack
For the Appellant
Mr. Jagmohan S. Gill, Q.C.
Ms. Donna Dorosh
For the Respondent
SOLICITORS OF RECORD:
Koskie Minsky
Box 52
900-20 Queen Street West
Toronto, Ontario
M5H 3R3
For the Appellant
George Thomson
Deputy Attorney General
of Canada
For the Respondent
FEDERAL COURT OF CANADA
Court No.: A-812-95
Between:
ALCO DISPENSING CANADA LTD. ET AL.
Appellant
- and -
Respondent
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