Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA) -- text

Urie, J (concurred in by MacKay and Kerr, DJJ):—This is an appeal from a judgment of the Trial Division dismissing with costs the appellant’s appeal from the respondent’s reassessment in respect of its 1969 taxation year. In its 1969 income tax

Antoine Hulmann v. Minister of National Revenue, [1977] CTC 201, 77 DTC 5153 -- text

Urie, J (per curiam) (judgment delivered from the Bench):—The question of whether or not the transaction of sale of a property is for the vendor’s capital or income account is dependent on the particular facts and circumstances surrounding the

Her Majesty the Queen v. Stefan Jachimowicz, [1977] CTC 162, 77 DTC 5148 -- text

Collier, J (orally):—For the 1972 taxation year the Minister of National Revenue added to the defendant’s income for tax purposes an amount of $176,185.91. The Minister characterized it as a “gain realized upon disposal of Cole Harbour land’’ and as a

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