Spruyt v. R., [1997] 3 C.T.C. 3070, 97 D.T.C. 1521 -- text
Rip T.C.J.:
Rip T.C.J.:
Garon T.C.J.:
Teskey T.C.J.:
1 The Appellant appeals from reassessments by the Minister of National Revenue (the “Minister”) of income tax in respect of its 1986, 1987 and 1988 taxation years.
Beaubier T.C.J.:
1 These appeals were heard together on common evidence by consent of the parties at Toronto, Ontario on November 17 and 18, 1997 pursuant to the General Procedure. The Appellants and their husbands testified on behalf of the Appellants. The Respondent called Lyle Faulkner, Tajinder Kooner and Donald Balanger, officers of Revenue Canada.
Watson, D.J.T.C.:
1 These appeals were heard on common evidence with consent of the parties in Toronto, Ontario on February 24, 1997.
Desjardins J.A.:
1 We are all of the view that this application for judicial review must fail.
Décary J.A.:
St. Onge T.C.J.:
1 The appeal of Mehernush Pourzynal was heard on the 5th of May, 1997, in the City of Ottawa, Province of Ontario. And the issue is whether the appellant is entitled to claim certain amounts as an equivalent to married amounts in her 1990 and 1991 taxation years under paragraph 118(1)(b) of the Act.
Linden J.A.& McDonald J.A.:
1 The issue in this appeal is whether Ford Motor Company of Canada, Limited (“Ford Canada”) ought to have been included in the expanded definition of “manufacturer or producer” in paragraph 2(1)(f) of the Excise Tax Act[FN1: <p>R.S.C. 1970, c. E-13 (as amended)</p>] (the “Act”) for the purposes of determining the tax payable on its imported vehicles. Paragraph 2(1)(f) provided:
2.(1) In this Act