Cedar Ridge Construction Ltd. v. The Queen, [1983] CTC 404 (FCTD) -- text
Collier, J [ORALLY]:—The motion to strike out the statement of claim is refused.
Collier, J [ORALLY]:—The motion to strike out the statement of claim is refused.
Jerome, ACJ:—This appeal from a decision of the Tax Review Board dated January 29, 1982, came on for hearing at Toronto, on February 23, 1983. At the conclusion of argument, I indicated that while I had some sympathy with the appellant, it
Collier, J [ORALLY]:—The appeal of the plaintiff is allowed. In 1977 the plaintiff company received an amount of $830,000. It was paid by Naden Harbour Timber Ltd (Naden), to the plaintiff as “damages for termination or cancellation” of an agreement dated March 6,
Strayer, J:—On June 24, 1981 the Minister of National Revenue issued a notice of reassessment of the plaintiff’s income tax for the 1976 taxation year. The plaintiff had reported a taxable capital gain in the amount of $431,513 with respect to the sale by
Le Dain, J:—This is an appeal from a judgment of the Trial Division allowing the respondent’s appeal from an income tax reassessment in respect of his 1972 taxation year.
Pratte, J:—The only argument put forward by Mr Campbell in support of the application was that the applicant, in manufacturing ready-mix concrete and concrete building blocks with the cement it had produced, had not used that cement within the meaning of
Cattanach, J:—These are three appeals from three assessments made by the Minister of National Revenue of the plaintiff’s income tax for his 1977, 1978 and 1979 taxation years whereby the Minister disallowed deductions for farming losses incurred and claimed by
Ryan, J:—This is an appeal from the order of the Trial Division dated November 10, 1980, dismissing an application by the appellant for an order in the nature of certiorari in respect of a stay of proceedings, filed under sub-
Dubé, J:—The central issue raised by this appeal is whether a bonus in the amount of $325,000 earned by the plaintiff company on a loan of $1,125,000 it made to WWW Developments Ltd (“WWW”) in 1974 was income of the plaintiff taxable in
Clement, DJ:—In this action the plaintiffs-appellants (whom I will call the Administrators) claim relief from taxation under the Income Tax Act by virtue of subsection 70(6) of which the following provisions are relevant: