Dufour v. MNR, 90 DTC 1238, [1990] 1 CTC 2351 (TCC) -- text
Tremblay, T.C.J.:—The hearing of this application for an extension of time was held on March 28, 1989, in Québec, Québec.
George E. Waugh, Jerry W. Higgins, K. Michael Lowther, Trevor S. Russell, Constance K. Duncan, Christopher G. Duncan, Ronald Rodrique, Alex Bodnar, Brian Smedley, Robert L. Brewin, Leslie H. Shumka v. Minister of National Revenue, [1990] 1 CTC 2346, 90 DTC 1117 -- text
Christie, A.C.J.T.C.:—This is a test case. It is agreed that its disposition shall apply to 11 other appeals. [1]
Richard B. Stursberg, A.L. Peter Stursberg, Jessmar Investments Ltd., Richard K.G. Stursberg, W.B.G. Developments Ltd., Margaret L. Sheardown, Noran M. Sheardown and Frances E. Duncan v. Minister of National Revenue, [1990] 1 CTC 2335, 90 DTC 1159 -- text
Mogan, T.C.J.:—The appellant was a partner in a general partnership formed under the laws of British Columbia and under the firm name and style "Kanvan Group" (the "Partnership"). The purpose of the Partnership was to purchase certain land; to plan,
Mark Harding v. Minister of National Revenue, [1990] 1 CTC 2322, 90 DTC 1169 -- text
Sarchuk, T.C.J.:—Mark Harding appeals from reassessments made by the respondent with respect to his 1979 to 1985 taxation years inclusive. Initially a number of issues were before me; however the parties have consented to judgment being issued by this Court
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.
The Douglas Jamison Caldwell Trust, the Susan Alexandra Caldwell Trust and the Derek Wilson Caldwell Trust v. Minister of National Revenue, [1990] 1 CTC 2310, 90 DTC 1155 -- text
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
Brad-Lea Meadows Ltd. v. MNR, 90 DTC 1269, [1990] 1 CTC 2306 (TCC) -- text
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
Grayson v. MNR, 90 DTC 1108, [1990] 1 CTC 2303 (TCC) -- text
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
Central Amusement Company Limited v. Minister of National Revenue, [1990] 1 CTC 2299, 90 DTC 1208 -- text
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
Cormier v. MNR, 90 DTC 1167, [1990] 1 CTC 2295 (TCC) -- text
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
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