Muldoon J.:—The Crown appeals by way of proceedings de novo, and states its case in its amended statement of claim, to which the defendant responds with marvellous brevity, but fully in five paragraphs on one page and a half. Counsel
MacKay J.:—In these four actions, consolidated for trial together on similar facts and raising the same issues, the plaintiff appeals from assessments as modified by reassessments of income tax for the taxation years from 1978 to 1981. Each of the actions relates to a particular taxation year, T-2607-87 to 1978, T-2608-87 to 1979, T-2609-87 to 1980 and T-2610-87 to 1981.
Hugessen J.A.:—This appeal requires this Court to rexamine the precise scope and reach of the provisions relating to amalgamation found in section 87 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act")
Hugessen J.A.:— We have not been persuaded that the learned motions judge committed any reversable error or acted on any wrong principle in the exercise of his discretion to allow the plaintiffs’ case, difficult though it may prove to be, to
Linden J.A.:—The issue in this application for judicial review is whether wage loss replacement amounts received by the applicant in 1990 and 1991 were payable to him in respect of a loss in consequence of an event occurring before 1974. If so,
l.:
Garland v. C.E.I.C., (1985) 63 N.R. 129, 23 D.L.R. (4th) 393;
McDonald J.A.:—These are appeals from a reported decision of the Trial Division ([1993] 1 C.T.C. 148, 93 D.T.C. 5067), which dismissed appeals from the reassessments of the appellant’s 1985 and 1986 income tax returns.
Hugessen J.A.:—These three appeals raise a problem that is common to all three cases. In addition, the appeal in file no. A-184-93, Faema Distributeur Inc., raises a question that is specific to that case.
All of the respondents import kitchen equipment that is intended for sale, and is in fact, sold to restaurant establishments. In addition, the respondent, Faema Distributeur Inc., imports kitchen equipment that is intended for sale, and is in fact sold, to people who will use it for strictly domestic and non-commercial purposes.
Robertson J.A.:—The respondent is a "Class 1” farmer who in 1987 transferred all his farmin assets to a company incorporated for the purpose of facilitating a "rollover" to his son on the former's death. Simply stated, the issue raised on this
Mahoney J.A.:—This is an appeal from a reported decision of the Tax Court of Canada (Schwartz v. Canada, [1993] 2 C.T.C. 2125, 93 D.T.C. 555), which allowed the respondent's appeal against the inclusion in his 1989 taxable income
