ETA Performance Systems Corp. v. MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC) -- text
Hamlyn, T.C.C.J. (orally):—This is an appeal from a reassessment for the 1985 taxation year.
Hamlyn, T.C.C.J. (orally):—This is an appeal from a reassessment for the 1985 taxation year.
Garon, T.C.C.J.:—Each of the appellants filed an application to strike out the reply to the notice of appeal. The texts of each of those applications are, to all intents and purposes, identical. At the hearing of these three applications, for reasons
Tremblay, T.C.C.J.:—This appeal was heard on September 16, 17 and 25, 1992, in Quebec City, Quebec.
Kempo, T.C.C.J.:—These appeals concern the appellant's 1987, 1988 and 1989 taxation years.
Bonner, T.C.C.J.:—The appellant Brian Morris seeks an order striking out paragraph 6(k) of the reply to the notice of appeal filed by the respondent. He appeals from an assessment of income tax for the 1988 taxation year. On assessment, the Minister
Hamlyn, T.C.CJ. (orally):—In the matter of Souhiel Saikely and the Minister of National Revenue, this is an appeal filed on November 7, 1988, with respect of the 1981, 1982 and 1983 taxation years.
Mogan, T.C.CJ.:—Mr. Peter De Verteuil and his wife Mrs. Reni De Verteuil commenced appeals in this Court concerning the deduction of legal expenses which they incurred in the taxation years 1987 and 1988. These appeals were heard on common evidence. The
Lamarre Proulx, T.C.CJ.:—The appellant has appealed from a reassessment by the respondent Minister of National Revenue (the"Minister") for the 1985 taxation year.
Tremblay, J.T.C.C:—This appeal was heard on April 7, 1992, in Sherbrooke, Quebec.
Hamlyn, T.C.C.J.:—The appellant purchased a residential unit (the''unit") and in January of 1988 sold the unit and made a profit of $47,292 (the ” profit"). The appellant's 1988 tax return (the "return") did not reflect the profit. In reassessing the appellant's return, the Minister of National Revenue (the"Minister") included the profit in the appellant's income. In addition, the Minister levied penalties (the " penalties”) under subsection 163(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act")..