Hogg v. The Queen, 87 DTC 5447, [1987] 2 CTC 257 (FCTD) -- text
Joyal, J.:—The plaintiff-taxpayer appeals from a tax reassessment issued by the defendant on May 24, 1983 covering the 1979 taxation year.
Joyal, J.:—The plaintiff-taxpayer appeals from a tax reassessment issued by the defendant on May 24, 1983 covering the 1979 taxation year.
Cullen, J.: —My colleague, McNair, J., granted the defendant the right to file a conditional appearance, contingent on a finding of jurisdiction of this court. Another colleague, Teitelbaum, J., heard argument from both parties and then adjourned the
Smith J. [Orally]:—The question in this proceeding is whether Judge J.D. Smith was right to stay proceedings in the prosecution of the accused Yogendra Sharma under section 239 of the Income Tax Act, the prosecution being under
Cullen, J.: —The trial of these matters was heard together and on common evidence.
Mahoney, J:—We are in agreement with the reasons for judgment of the learned trial judge herein. The appeal will be dismissed with costs.
Appeal dismissed.
Stone, J.:—This is an appeal from the judgment of Reed, J. in the Trial Division rendered February 13, 1985 ([1985] 1 C.T.C. 192; 85 D.T.C. 5144) whereby a claim in respect of the years 1972 through 1977 that a particular capital property of
Hugessen, J.:—We are all of the view that the trial judge committed no manifest error that could be a basis for intervention by this Court when he held that the sum of $936,512 received by the respondent in 1974 was only an advance on
Reed, J.: —The issue in this case is a very narrow one: whether the “thin capitalization rules" apply to limit the amount of interest the plaintiff can claim as an expense as against its income for the 1978 taxation year.
Dubé, J.: —By this income tax appeal the plaintiff (at times referred to as "Speedy Muffler”) claims that its activities in assembling and installing exhaust systems on motor vehicles constituted an active business of manufacturing and processing goods for
Maher, J: —In these matters three applications are made for a determination as to whether the actions by The Minister of National Revenue (hereinafter referred to as "the Minister”), directing that the applicant taxpayers forthwith pay the amounts of