David J. Groeneveld v. Minister of National Revenue, [1990] 1 CTC 2314, 90 DTC 1211 -- text
Kempo, T.CJ.:—These appeals concern the appellant's 1979, 1981 and 1982 taxation years and were heard on common evidence.
Kempo, T.CJ.:—These appeals concern the appellant's 1979, 1981 and 1982 taxation years and were heard on common evidence.
Bonner, T.CJ.:—The appellants appeal from assessments of income tax for the 1981, 1982 and 1983 taxation years. At issue is the appropriate treatment of certain dividends. During the first two years the appellants held all the issued shares of Prince
Brulé, T.C.J.:—This is an appeal from a notice of assessment for the taxpayer's 1985 taxation year in which the Minister considered an affiliation fee paid to Best Western International Inc. to be a royalty and therefore subject to tax within the
Kempo, T.C.J.:—These appeals concern the appellant's 1985 and 1986 taxation years wherein the respondent had reassessed the appellant's income so as to add the amount of $10,795.37 to his 1985 income and the amount of $17,041.95 to his 1986 income on
Christie, A.C.J.T.C.:—This appeal relates to the appellant's 1983 taxation year. The issue is whether, in computing its income for that year, the appellant is entitled to deduct expenditures that it made of $175,026 as currently deductible expenses. In reassessing
Mogan, T.C.J.: — The issue in this appeal is whether an amount of $36,950 received by the appellant in 1981 in connection with the sale of a business in 1978 is a “retiring allowance” within the meaning of subparagraph 56(1)(a)(ii) of the
Tremblay, T.C.J.:—This appeal was heard on common evidence with the appeal of Monique Beauregard (87-646 (IT)) in Montréal, Quebec on October 14, 1988.
Lamarre Proulx, T.C.J.:—The appellant is appealing from an assessment by the respondent, Minister of National Revenue, made pursuant to section 227.1 of the Income Tax Act, ("the Act”).
Tremblay, T.C.J.: —This appeal was heard on November 23, 1988 at the City of Montreal, Québec.
Bonner, T.CJ.:—This is an application by way of interlocutory motion for judgment vacating the assessments under appeal on the ground that the delay in hearing the appeals is so great and so unreasonable that (a) the appellant's rights under paragraph