NRB Inc. v. The Queen, 93 DTC 295, [1993] 1 CTC 2435 (TCC) -- text
Hamlyn, T.C.C.J.:—
Facts
The appellant, NRB Inc., appeals reassessments dated May 16, 1990, in respect of its 1986, 1987 and 1988 taxation years.
Hamlyn, T.C.C.J.:—
The appellant, NRB Inc., appeals reassessments dated May 16, 1990, in respect of its 1986, 1987 and 1988 taxation years.
Mogan, T.C.C.J.:— The appellant is an employee of Adventure Tours, a division of Akard Enterprises Ltd., a Quebec corporation engaged in the business of vacation travel. Adventure Tours assembles and sells tour packages to popular vacation destinations. These tour
Lamarre Proulx, T.C.C.J.:—This appeal was heard at the same time as the following appeals:
Gladstone Investment Corporation (91-203),
Loudee Holdings Inc. (91-205),
Bell, T.C.C.J.:— The appellant was formed by an amalgamation, on August 12, 1987, of a number of corporations including Campbell Red Lake Mines Ltd. (“Campbell Red Lake"). The appeal relates to notices of reassessment dated December 7, 1989, January 18,
Rowe, D.T.C.C.J.:—The appellant appeals from an assessment of income tax for his 1986 taxation year whereby the respondent included into income the sum of $64,022.19 as funds or property of David Robinson Ltd. having been appropriated by the appellant and
Lamarre Proulx, T.C.C.J.:— These appeals were heard on common evidence. The appeals concern the 1985, 1986 and 1987 taxation years. The point at issue is whether the purchase and sale of two buildings is an adventure in the nature of trade
Dussault, T.C.C.J.:— These are appeals from assessments for the appellant's 1984, 1985 and 1986 taxation years. In these assessments, the Minister of National Revenue (the "Minister") refused to allow the appellant the small business deduction provided in section
Lamarre Proulx, T.C.C.J.:— The appellant has instituted an appeal from the assessments made by the respondent, the Minister of National Revenue (the "Minister"), for 1984 and 1985.
Lamarre Proulx, T.C.C.J.: Il s'agit d’une requête pour procéder in forma pauperis.
Christie, A.C.J.T.C.:—There are two issues to be determined. First, was the profit of $13,300 on the disposition in 1986 of 153 Mooregate Crescent, Kitchener, Ontario, ("the Mooregate property”) a capital gain or business income. The second issue is the same