Lamarre Proulx, J.T.C.C.:— These two appeals were heard on common evidence. The taxation years in issue are 1982, 1983, 1984 and 1985.
Garon, J.T.C.C.:—This is an appeal under the informal procedure from an assessment of the Minister of National Revenue dated August 9, 1991 for the appellant’s 1988 taxation year. By that assessment the Minister of National Revenue included in the appellant’s income $75,000 received from Métro- Richelieu Inc. ("Métro"), whereas the appellant had considered that the amount was the proceeds of disposition of eligible capital property and as such had included the sum of $36,560 in its income.
Rip, J.T.C.C.:—Avis Immobilien G.M.B.H. ("Avis"), a non-resident of Canada, was assessed tax for 1986 pursuant to subsection 115(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). Avis has appealed the
Christie, A.C.J.T.C.C.:—The year under review is 1987. These appeals were heard together on common evidence. The appellants are husband and wife. The core issue is the appellants’ liability to income tax on amounts realized by them related to the disposition
Lamarre, J.T.C.C. (orally):—This is an appeal under the informal procedure from a reassessment issued by the Minister of National Revenue (hereinafter "the Minister"), in respect of the appellant's 1991 taxation year.
Sarchuk, J.T.C.C.:—This is an appeal from reassessments of tax for the 1987 and 1988 taxation years by virtue of which the Minister of National Revenue (the Minister) disallowed the deduction by the appellant of certain legal and accounting fees incurred
Mogan, J.T.C.C.:—The subject of this appeal with respect to the appellant's 1987 taxation year is an inducement payment by a landlord which requires an interpretation of paragraph 12(1)(x) of the Income Tax Act, R.S.C. 1952, c. 148
O’Connor, J.T.C.C.:—These appeals were heard in Ottawa, Ontario on October 19, 20 and 21, 1993 pursuant to the general procedure of this Court and relate to the appellant's 1986, 1987, 1988 and 1989 taxation years. In assessing, the Minister of National
Bowman, J.T.C.C.:—This appeal, from an assessment for the appellant’s 1986 taxation year, raises once again the question of the treatment under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), prior to the coming
Brulé, J.T.C.C.:—The appellant has objected to the disallowance by the Minister of National Revenue ("Minister") of interest deductions paid in the 1985 and 1986 taxation years pursuant to paragraph 20(1 )(c) of the Income Tax Act, R.S.C.
