Rip J.T.C.C.:—This appeal from an income tax assessment for the 1985 taxation year of Duha Printers (Western) Ltd. ("Duha #3") turns on whether there was a change in control before February 9, 1984 of Duha #2, a corporation formed under the laws
Brulé J.T.C.C.:-These two appeals involve the same appellant but were commenced at a time when the provisions of the Tax Court of Canada Act were changed, hence two separate designations. The appeals were heard on common evidence
Sobier J.T.C.C.:-The Court is now prepared to give judgment and reasons for judgment in the matter of Roy W. Craik v. The Queen, number 92-1363G.
Beaubier J.T.C.C.:-This matter was heard in Edmonton, Alberta on October 17, 18 and 19, 1994 pursuant to the general procedure of this Court.
Beaubier J.T.C.C.:—This matter was heard pursuant to the rules of general procedure at Calgary, Alberta on September 20, 1994. The parties filed an agreed statement of facts and the appellant testified.
Christie A.C.J.T.C.C.:-The issue in this appeal is whether the appellant’s share of the profit on the disposition of the Swansea Shopping Centre, also sometimes known as the Southport Shopping Centre, 34 Southport Street, Toronto (’’the property"), is a capital gain or business income.[1] In his return of income the appellant reported his share as a capital gain. The respondent reassessed on the basis that it was business income.
Rowe D.J.T.C.C.:—This appeal was heard under the General Procedure of this Court.
Mogan J.T.C.C.:-This case was commenced when Carole Ann Walker (the appellant) filed a notice of appeal from certain income tax assessments. The Minister of National Revenue (the Minister) made an application to this Court under section 174 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the ’’Act") (i) for an order joining Roy S. Shattock (the former husband of Carole Ann Walker) as a third party to her appeal; and (ii) for the determination of certain questions set out in the Minister’s application.
Kempo J.T.C.C.:-This informal procedure appeal concerns the appellant’s 1989, 1990 and 1991 taxation years.
Bowman J.T.C.C.:—These appeals from assessments for the 1989 and 1990 taxation years were heard together. The issue is whether the Minister of National Revenue was justified in allocating a portion of the interest expense claimed by Mr. and Mrs. Tsiantoulas to
