Jake Friesen v. Her Majesty the Queen, [1992] 1 CTC 296, 92 DTC 6248 -- text
Rouleau, J.:—Mr. Jake Friesen is appealing the reassessments of business income by the Minister of National Revenue for the 1983 and 1984 taxation years.
Rouleau, J.:—Mr. Jake Friesen is appealing the reassessments of business income by the Minister of National Revenue for the 1983 and 1984 taxation years.
Joyal, J.:—The plaintiffs appeal from Revenue Canada's tax reassessment for the year 1983 adding to their income certain benefits received by the plaintiffs from their employer, Turbo Resources Ltd. The nature of these benefits, taxable under paragraph 6(1)(a) of
MacGuigan J.A. (Heald and Linden, l].A., concurring.):—This case deals with an issue of tax timing similar to that recently decided by this Court in West Kootenay Power and Light Company Ltd. v.
Hugessen, J.A.:—The learned trial judge concluded that the appellant's dealings in the shares of Dome Petroleum were those of an investor for capital account rather than those of a trader or speculator. To reach this conclusion the judge weighed the
Hugessen, J.A.:— We are all of the view that the learned trial judge reached the correct result. The appellant would have us read subsection 13(7.1) [1] of the Income Tax Act, R.S.C. 1952, c. 148 (am.
Mahoney, J.A.:—We are in agreement with the interpretation the learned trial judge has placed on the term” reimbursement" in paragraph 12(1)(x)(iv) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act").
Cullen, J.:—This is an appeal from a reassessment of tax for the plaintiff's 1981, 1982, 1983 and 1984 taxation years. In the reassessment the Minister of National Revenue disallowed the amounts claimed by the plaintiff for the deduction of a reserve
Collier, J.:—This is an appeal, by the plaintiff taxpayer, in respect of income tax assessments issued by the Minister of National Revenue.
The Associate Chief Justice:—This appeal by way of trial de novo from a decision of the Tax Court of Canada dated September 25, 1986 came on for hearing at London, Ontario on October 1, 1991. The plaintiff appeals the
Rouleau, J.:—In this action the plaintiff appeals the decision of the Associate Chief Justice of the Tax Court, dated January 18, 1990, which held that certain expenditures made by the plaintiff during its 1983 taxation year were payments made on account