Gerol v. A.G. Canada, 85 DTC 5561, [1986] 1 CTC 75 (S.C.O.) -- text
Rosenberg, J. [ORALLY]:—
Rosenberg, J. [ORALLY]:—
Stone, J.:—This appeal and cross-appeal from a judgment of the Trial Division raise two separate issues concerning the interpretation of section 125.1 of the Income Tax Act, S.C. 1970-71-72 c. 63 as amended as well as certain of
McNair, J.:—The sole issue in these consolidated actions is whether the sum of $60,343 paid to the plaintiff, Phillipe E. Delesalle, on his retirement from the architectural firm of Cohos, Delesalle & Evamy, was income or a payment on account of
Mahoney, J.:—In issue is the right claimed by the appellant to deduct from its taxable income otherwise calculated, for its taxation year ended December 31, 1978, an amount of $707,143. During the year, the appellant paid $1,414,286, being the par value
Strayer, J.:—This is an appeal by the taxpayer from a decision of the Tax Court of Canada with respect to assessments of his tax for the 1979 and 1980 taxation years. The Minister disallowed as deductions from income automobile expenses in the
Langdon, Prov. Ct. J.:—The defendants are charged in one information, each with two separate counts under subsection 238(2) of the Income Tax Act. Counts 1 and 2 relate to McKinlay Transport Limited (hereinafter referred to as
Thomas, Prov. Ct. J. [ORALLY]:—Gentlemen, with respect to all the motions which were before me, I will deal with them not necessarily in the order in which they were argued, but perhaps in the order in which they were presented, with
Joyal, J.:—This is a trial pursuant to Rule 475 of the Federal Court Rules on a case stated by the parties with respect to the imposition of an excise tax on certain transactions involving cost-sharing programs undertaken between the Federal Government
Reed, J.:—This is an appeal from a decision of the Tax Court of Canada finding the claimant liable for unpaid income taxes for the years 1978, 1979, 1980 and 1981. The unpaid tax liability arises out of net worth assessments prepared by the
Collier, J.:—This is an appeal, on behalf of the Minister of National Revenue, from a finding of the Tax Review Board in favour of the defendant taxpayer, in respect of an income tax assessment made by the Minister for the 1979 taxation year.