Philrick Limited v. Her Majesty the Queen, [1977] CTC 217, 77 DTC 5158 -- text
Sweet, DJ:—This appeal from the plaintiff’s income tax reassessments for its 1967, 1968, 1969 and 1970 taxation years has two parts.
Sweet, DJ:—This appeal from the plaintiff’s income tax reassessments for its 1967, 1968, 1969 and 1970 taxation years has two parts.
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
Seaton, JA:—The executors of the estate of the late Mr Whittall appeal from a decision that certain life insurance policies are to be included in the estate for succession duty purposes.
The Chief Justice (per curiam) (judgment delivered from the Bench):—We have concluded that it is not necessary to hear counsel on the second branch of the case.
Urie, J (per curiam) (judgment delivered from the Bench):—For the reasons given in the appeal of Antoine Hulmann v MNR (Court No A-275-75), the appeal will be dismissed. There will be no costs on this appeal.
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
Gibson, J:—This is an appeal by the Deputy Attorney General of Canada on behalf of the plaintiff from the decision of the Tax Review Board dated July 11, 1974 which allowed the appeal of the defendant Cadboro Bay Holdings Ltd from a
Decary, J:—This is an appeal to this Court from a judgment of the Tax Review Board whereby an amount of $378,000 received by plaintiff from the Government of the United States of America, for licence to use background data and for licence
Addy, J:—The issue in the present case is a very narrow one. It turns entirely on whether the words “structural building sections’’ as found in subsection 26(4) of the Excise Tax Act, RSC 1970, c E-13, are applicable to
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