Bowman, J.T.C.C.:—These appeals were heard together and are, in the case of Otineka Development Corp., from an assessment for 1986 and, in the case of 72902 Manitoba Ltd., from assessments for 1986 and 1987. In both cases the issue is whether the
Archambault, J.T.C.C.:—The only issue raised by the appeal of the appellant is the penalty 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") in connection with undisclosed income
Sobier, J.T.C.C.:—The appellant appeals from the assessment by the Minister of National Revenue (the "Minister"), for his 1988 and 1989 taxation years, whereby the Minister included in his income for 1988, the amount of $72,917, and for 1989, the amount
Sobier, J.T.C.C. (orally):—The Court is now prepared to give reasons for judgment in the matter of Harris Steel Group Inc. v. The Queen, 91-1669G.
Sobier, J.T.C.C.:—The appellant appeals from the assessments by the Minister of National Revenue (the "Minister") for his 1990 taxation year whereby the Minister included in his income for that year, an amount equal to the amount the appellant became entitled to on deregistering a registered retirement savings plan (the "RRSP").
The parties filed an agreed statement of facts and the relevant portions are set out below:
Rip, J.T.C.C.:—In computing her income for 1991 Jo-Anne McCluskie ("McCluskie") deducted child care expenses of $10,205.78. The Minister of National Revenue ("Minister"), in reassessing McCluskie, reduced the amount of child care expenses deductible in computing her income
Teskey, J.T.C.C.:—The appellant appeals his assessments of income tax for the years 1986, 1987 and 1988. These appeals were heard under the General Procedure Rules.
The two issues before me are:
1. Whether a benefit was conferred by ASDCO Holdings Inc. ("Holdings") on the appellant in his capacity as a shareholder of Holdings within the meaning of section 15 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), and
Bell, J.T.C.C. (orally):—The decision which I must make in this case is based entirely upon fact. In my opinion, the valuation that I must determine in respect of the transaction in question of land transfer by the appellants to Duncan Associates Ltd. in January
McArthur, J.T.C.C. (orally):—This appeal was heard in Regina, Saskatchewan on December 8, 1993, pursuant to the general procedure of this Court. The appellant, Daniel F. Glass, appeals the penalties imposed by the Minister of National Revenue for 1988 and
Brulé, J.T.C.C.:—These appeals, heard on common evidence under the informal procedure provisions of the Tax Court of Canada Act, R.S.C. 1985 c. T-2, involve the Minister of National Revenue ("Minister") reassessing the appellants
