Qualico Developments LTD v. Her Majesty the Queen, [1983] CTC 66, 83 DTC 5108 -- text
Décary, J:—In this matter, the facts were agreed upon:
Décary, J:—In this matter, the facts were agreed upon:
Mahoney, J:—The defendant was a Canadian resident, employed by a Canadian corporation Tranter Canada Ltd, a wholly owned subsidiary of Tranter, inc [sic], hereafter “Tranter”, a Michigan corporation. On January 28, 1976, Tranter granted the defendant an option to
Mahoney, J:—The plaintiff acquired a block of 59.3 acres of land on the southerly extremity of the City of Edmonton on November 27, 1961, at a price of $4,000 per acre. Certain of the land was expropriated after acquisition. On February 1,
Mahoney, J:—The first issue is whether a “portable” asphalt plant, acquired by the plaintiff in its 1974 taxation year and first used in its 1975 taxation year, generated “Canadian manufacturing and processing profits” for purposes of subsection 125.1(1) of
Dubé, J:—The plaintiff, a resident of Switzerland, appeals the assessments for his 1971 and 1972 taxation years including the total sums of $1,116,712.10 and $934,691.04 respectively as income from a “money lending business carried on by him in Canada”.
Thurlow, CJ:—The issue in this appeal is whether the taxable income of the respondent for the taxation years 1972, 1973, and 1974, when the respondent did not qualify for a tax deduction as a Canadian controlled private corporation, must be brought
Jerome, ACJ:—This is an action by way of appeal from a decision of the Tax Review Board, made at Edmonton, Alberta, on May 29, 1980. I heard evidence and submissions of counsel at Edmonton on May 28, 1982 and held the matter under
Dubé, J:—The main issue to be resolved here is whether the sale of the plaintiff's property to one Jack Mendlewitz took place on October 29, 1968 as alleged by the plaintiff, or on September 10, 1970 as assumed by the Minister, and therefore
Heald, J:—This is an appeal from an interlocutory judgment of the Trial Division which:
Heald, J:—Rule 447(2) required the respondent to file and serve on the appellant a list of documents specified therein within 20 days after the pleadings in the action were deemed to be closed. It is common ground that this was not done on a timely