Tremblay, TCJ:—This case was heard on October 23, 1984 in the City of Montreal, Quebec, and was taken under advisement on November 28, 1984 on reception of the transcript.
Sarchuk, TCJ:—This is an appeal by the Executor of the Estate of Adam Koziej from an assessment by the Minister of National Revenue with respect to the 1979 taxation year. The relevant facts are not in dispute. Mr J W May (May) was
Bonner, TCJ [ORALLY]:—These are appeals from assessments of income tax for the 1979, 1980 and 1981 taxation years. The assessments were made on the basis that section 31 of the Income Tax Act applies to limit the deductibility
Taylor, TCJ:—These are appeals heard on common evidence at Toronto, Ontario on September 23, 1985, against income tax assessments, in which the Minister of National Revenue assessed as taxable income the proceeds from Registered Home Ownership
Taylor, TCJ: —This is an application for extension of time within which to file a notice of objection, which was heard in Toronto, Ontario on September 23, 1985. There were several technical points raised by the taxpayer and by counsel for
Goetz, TCJ:—This is an appeal by the appellant from an assessment of its 1980 income tax return by the Minister of National Revenue. The assessment involves the appreciation in value of certain hotel property owned by the appellant, the sale of
Christie, ACJTC:—This appeal is against a reassessment by the respondent under the Income Tax Act ("the Act") regarding the appellant’s 1977 taxation year. In reassessing, the respondent disallowed a claimed deduction by the appellant for
Couture, CJTC [ORALLY]:—After having heard the evidence of Mr Connell and having regard to the present jurisprudence in the decisions of the Federal Court of Appeal in The Queen v Paul E Graham and of the Federal
Taylor, TCJ :—This is an appeal heard in Toronto, Ontario, on September 23, 1985, against an income tax assessment, in which the Minister of National Revenue imposed a late filing penalty of $9,705 under subsection 162(1) of the Income
Rip, TCJ:—The facts in Mr Steven Adam's appeal from an income tax assessment for 1982 are not in question. The issue is whether a salary, once paid as salary, can be made retroactively into a dividend.
