M v Donna Rae Limited v. Minister of National Revenue, [1980] CTC 2333, [1980] DTC 1284 -- text
John B Goetz:—This is an appeal against a reassessment relating to the appellant’s 1976 taxation year.
John B Goetz:—This is an appeal against a reassessment relating to the appellant’s 1976 taxation year.
Roland St-Onge [TRANSLATION]:—The appeal of Cécile Cliche-Paquet came before me on December 6, 1979 in Quebec City, Quebec and was heard on common evidence with the appeals of Annette Henry, Lucette Gosselin, Claire Pedneault and Claudette Dionne.
Roland St-Onge [TRANSLATION]:—The appeals of Mr François Durocher and of Indépendant Gaz Service Inc came before me on February 14,1980 in Montreal, Quebec. The points at issue in the case of Mr François Durocher are as follows:
The Assistant Chairman:—Had section 60.1 of the Income Tax Act (as amended by tax reform) not been put into that Act, this case would never have been appealed as the claim the appellant is asserting clearly is not
The Assistant Chairman:—While it would appear that the appellant appealed from an assessment for income tax for each of the years 1973,1974 and 1975, it is obvious no appeal was necessary for the 1973 year as the appellant’s objection to that
D E Taylor [TRANSLATION]:—This is the appeal of Jean Bouchard for 1976 concerning his withdrawal of the amount contributed by him to his home ownership savings plan. The facts are very clear and are set out in Mr Bouchard’s letters and
D E Taylor [TRANSLATION]:— This is my decision concerning the appeals of Rodin Lemerise against tax assessments for 1971, 1972, 1973 and 1974. The amounts in dispute are different in each of the four years and do not involve exactly the
The Assistant Chairman:—The appellant, when it filed its income tax return for each of the years 1973 and 1974, in effect took the position that its principal business was that of “leasing, rental, development, sale or any combination thereof, of
Guy Tremblay:— This case was heard in Vancouver, British Columbia, on February 20, 1979.
The Chairman:—This is the appeal of Lome Victor Ardley from assessments in respect to the 1973, 1974, 1975 and 1976 taxation years by which the Minister of National Revenue disallowed amounts of $6,173, $7,670, $8,100 and $7,800 claimed by the appellant,