Taylor, J.T.C.C. (orally):— Well I think it is obvious that I am neither a soothsayer, or Solomon, and there is no logical, rational or reasonable way to arrive at a conclusion in this case which could be statistically and arithmetically
Kempo, J.T.C.C.:— These general procedure appeals concern the appellant’s 1987 and 1988 taxation years ending January 31, 1987 and January 31, 1988, respectively.
Bowman, J.T.C.C.:— These cases were heard together on common evidence and involve appeals from assessments for 1985, 1986, 1987 and 1989 as well as from a determination of loss for 1988.
Beaubier, J.T.C.C.:—This matter was heard in Toronto, Ontario on March 22 and 23, 1994. It is an appeal pursuant to the General Procedure of this Court. The appellant ("Antrex") called as witnesses Antonio Montemarano, its president and director, and Thomas Hall, C.A.,
Christie, A.C.J.T.C.C.:—The parties agreed in writing to these facts:
I. The appellant filed his returns of income for the 1987 and 1988 taxation years on April 28, 1989. The appellant's return of income for the 1987 taxation year was required to be filed by April 30, 1988.
Teskey, J.T.C.C.:— The appellant appeals its assessment of income tax for its fiscal year ending December 31, 1982.
Mogan, J.T.C.C.:— The appeals of Moffat v. The Queen (court file 92-1286), and 398827 Ontario Ltd. v. M.N.R. (court file 90-1253), were heard together on common evidence. In these reasons for
Hamlyn, J.T.C.C.:—The essence of these appeals lies with the taxpayer’s disagreement with the fair market value determined by Revenue Canada on real properties transferred, as well as, in particular whether the appellant had a beneficial interest in two of the
McArthur, J.T.C.C.:— Joint Trawlers Inc. (the "company") paid cash dividends to its only two shareholders Marget Davis and Herbert Davis in 1985 and 1986. On November 11, 1986, the company was assessed a total tax liability of $36,543.88 for its 1985
Bowman, J.T.C.C.:—This appeal is from an assessment for the appellant's 1989 taxation year. It has to do with the deductibility of certain expenses or losses incurred by him in connection with a vessel which he intended to use in a fishing
