Joyal, J.:—The issue before this Court is to determine if a payment of $2,772,217 by the plaintiff in the taxation year 1978 is in the nature of a deductible expense or an outlay on account of capital pursuant to the provisions of the
Dubé, J.:—This appeal seeks to reverse a decision of the Tax Court of Canada [1] , holding that the respondent only owed tax on half the taxable capital gain from the disposition in 1982 of real estate which was part of
Stone, J.A.:—This appeal from a judgment of the Trial Division rendered July 28, 1987, raises an issue whether the appellant, which carried on a life insurance business in Canada in the taxation year 1976, also carried on an insurance business in
Pinard, J.: —In this action, pursuant to subsections 172(1) and 175(3) of the Income Tax Act, S.C. 1970-71-72, c. 63 as amended, the plaintiff is appealing from a decision of the Tax Court of Canada which dismissed her two appeals
Hugessen, J.A.:—Though the reasons given by the Tax Court of Canada judge in support of his refusal to exercise his discretion to extend the deadline are not beyond all criticism, we all consider that the result at which he arrived is the
The Associate Chief Justice:—The style of cause in this matter was amended by order of Giles, A.S.P. on September 11, 1989, unfortunately to reflect the fact that the plaintiff William J. Vine died on May 2, 1989 while judgment was
Jerome, A.C.J.: —I'm not going to call on you, Mrs. Goldstein.
I'm sorry, gentlemen, I can't allow the appeal.
Heald, J.A.: — In spite of the able and extensive argument by counsel for the appellant, we are not persuaded that the learned trial judge committed reviewable error, either in his appreciation of the factual situation in this case or in
Heald, J.A.: — We have not been persuaded that the learned trial judge has committed any error that would require the intervention of this Court.
Joyal, J.:—This is an action instituted by the plaintiff in 1977 and which finally came on for trial in Vancouver on October 3, 1989. It is an income tax matter relating to the taxation years 1970 and 1971. In each of those years, the
