Her Majesty the Queen, v. M. Geller, Inc., , [1963] CTC 438, [1963] DTC 1274 -- text
TASCHEREAU, J. (all concur) :—Section 80A (R.S.C. 1927, e. 179 and amendments) provides that:
TASCHEREAU, J. (all concur) :—Section 80A (R.S.C. 1927, e. 179 and amendments) provides that:
CARTWRIGHT, J.:—This is an appeal from a judgment of Cameron, J. dated March 17, 1954 declaring that the respondent is entitled to recover $573.08 excise tax together with certain penalties and costs.
The action was brought for the purpose of determining whether the product sold by the appellant and described as ‘‘mouton’’ was subject to tax under Section 80A of the Excise Tax Act which, so far as relevant, reads as follows :
NOEL, J.:—This is an application made by the appellant to amend his Notice of Appeal by deleting paragraph 9 of Part A and paragraph 6 of Part B of the said Notice and substituting a new paragraph 9 and 6 as follows:
CATTANACH, J.:—This is an appeal against the appellant’s income tax assessments for the taxation years 1957 and 1958, whereby the Minister added the sums of $222,619.33 and $7,606.47 as the estimated profit element on the sale of a shopping centre, known as
DUMOULIN, J.:—This is an appeal from the confirmation by respondent, on October 31, 1962, of an estate tax assessment, dated June 16, 1961, wherein a tax in the sum of $226,841.69 was levied on the estate of Robert Newmareh Hickson, Province of Quebec.
KEARNEY, J.:—The late Dame Adolorata Fabi died on February 18, 1957 and this appeal concerns two assessments to tax against her estate on profits arising from the sale of land described as Part of Lots 4 and 5 in the Township of Orford near the City of Sherbrooke, in the Province of Quebec, during the years 1955 and 1956, whereby the sums of $441.11 and $6,272.84 respectively were added to the appellant’s previously declared income for the said years.
KEARNEY, J.:—The present case concerns an appeal from assessments to tax whereby the Minister added certain amounts (later mentioned) to the appellant’s taxable income for each of the years 1955 to 1958 inclusive, on the grounds that the said amounts constituted
CATTANACH J.:—This is an appeal from the appellant’s income tax assessments for the taxation years 1956, 1957, 1958 and 1959.
CATTANACH, CATTANACH, J.:—This is an appeal from the decision of the Income Tax Appeal Board, sub nom. No. 544 v. M.N.R., 20 Tax A.B.C. 29, allowing the respondent’s appeals against his income tax assessments for the taxation
KEARNEY, J.:—We are here concerned with two separate appeals from income tax assessments levied by the Minister upon the appellant for the year 1952 (case No. 160170) and for 1953 (case No. 160171). Both notices of appeal were filed in this Court on