Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085, [1991] 1 CTC 197 (FCTD), aff'd 91 DTC 5543 (FCA) -- text
Cullen, J.:—
Cullen, J.:—
Dickson, C.J. [Per Coram]:—This is an income tax case. The question in the appeal is whether certain dividends received by the wife of the respondent, Jim A. McClurg, in the years 1978,1979, and 1980 in respect of Class B common
Reed, J.:—This is an appeal from a judgment of the Tax Court of Canada dated March 25, 1987, dismissing the plaintiff's appeal from income tax assessments for the taxation years 1982 and 1983. The appeal concerns maintenance payments of $7,380 and $5,760,
Pinard, J.:—This is an appeal by the plaintiff from the reassessment made by the Minister of National Revenue, which served to deny International- Import Customs Brokers Inc. the right to deduct pursuant to subparagraph 20(1)(c)(i) of the Income
Reed, J.:—The issue in this case is a very narrow one: did the plaintiff's purchase of the freehold interest in 200 acres of cranberry lots, on October 14, 1980, result in a merger of that interest and a prior profit à prendre the
Reed, J.:—The issue in this case is whether certain sums ($880,000 and $1,000,000) paid to the plaintiff, in the years 1983 and 1984 respectively, on account of the early termination of leases should be treated for tax purposes as capital gains or as business
Mahoney, J.A.:—This is an appeal from a judgment of the Trial Division which, on a preliminary argument, dismissed the appellant's action for declaratory relief without hearing evidence. That judgment is reported [[1990] 1 C.T.C. 71; 90 D.T.C. 6080] so it
Jerome, A.C.J.:—This action by way of appeal from a judgment of the Tax Court of Canada dated March 27, 1986, [[1986] 1 C.T.C. 2385; 86 D.T.C. 1312] came on for hearing at Edmonton, Alberta on June 21, 1990. At issue is whether profits
Stone, J.A. (Marceau and MacGuigan, JJ.A. concurring):—This is an appeal from a judgment of Reed, J. in the Trial Division rendered September 28, 1988 [[1988] 2 C.T.C. 312; 88 D.T.C. 6469]. By that judgment, the respondent's claim against a decision of
Décary, J.A.:—This is an appeal from an order by Collier, J. by which he allowed a motion by the respondent/plaintiff to compel the appellant/ defendant to produce certain documents, which she refused to disclose pursuant to subsection 241(1) of the