Prince Rupert Hotel (1957) Ltd. v. The Queen, 95 DTC 5227, [1995] 2 CTC 212 (FCA) -- text
Strayer J.A.:—
Strayer J.A.:—
MacKay J.:-In these two actions, heard together in accord with an order that they be joined for purposes of trial, the plaintiff, The Queen, appeals from a decision of the Tax Court of Canada. By that decision the appeals of the defendants were
Tremblay-Lamer J.:—This is an action commenced by the taxpayer to appeal from an income tax assessment made by the Minister of National Revenue for the 1979 taxation year. The plaintiff is a corporation in the commercial and industrial construction business. It
Rothstein J.:—The issue in this tax case is whether the gain on the sale of a commercial building by the plaintiff should be treated as a capital gain or as income.
Hugessen J.A.:—This is an appeal from a judgment of the trial division which allowed the respondents’ appeals against their assessments for income tax. The sole question before the trial division was to know whether a certain chemical pulp mill was a
Rothstein J.:—This is an appeal from a decision of Garon J.T.C.C. who dismissed the plaintiff's appeal from reassessment by the Minister of National Revenue for the taxation years 1981, 1982, 1983 and 1984. The issues are whether a land development business
Wetston J.:-This is an appeal from a notice of reassessment, dated September 30, 1985, in respect of the plaintiffs 1981 taxation year, whereby the Minister of National Revenue (the "Minister") reassessed the plaintiff’s tax liability by including, in income, an
Rothstein J.:-This is a review, pursuant to subsection 231.2(5) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), of an order of Muldoon J., a judge of this Court. The sequence of events giving rise to this review are as follows:
Rothstein J.:-Th is is an application for an order suspending the operation of orders made pursuant to section 231.2 of the Income Tax Act requiring the respondents to provide information relating to unnamed persons. The motion states that the orders have been appealed to the Federal Court of Appeal and that it is just in the circumstances to suspend the orders pending appeal. Reliance is placed on Rule 341 A.
Rothstein J.:—This is an appeal by way of trial de novo from a decision dated February 26, 1992 of Judge Taylor of the Tax Court of Canada, in which he allowed the appeal of the taxpayer ("Lehmann") against assessments made