C.B.A. Engineering Limited v. Minister of National Revenue, [1971] CTC 504, [1971] DTC 5282 -- text
CATTANACH, J.:—These are appeals by the appellant herein against its assessments to income tax for the taxation years 1964 and 1965.
CATTANACH, J.:—These are appeals by the appellant herein against its assessments to income tax for the taxation years 1964 and 1965.
Noël, A.C.J.:—By notice of motion, the Minister of National Revenue applies for an order quashing the appeal of the appellant herein, Vineland Quarries & Crushed Stone Limited (hereinafter sometimes called ‘‘Vineland’’) from an income tax assessment dated September 15, 1967, wherein tax in the sum of $2,268.43 was levied in respect of income for the taxation year 1965, on the basis that:
WALSH, J.:—This is an appeal from a notice of re-assessment in respect of the 1965 taxation year of the taxpayer wherein $380,000 was included in his income for that year. The taxpayer died on August 27, 1965 in Ontario where he had formerly carried on the practice of law in the City of Toronto and at the date of his death amounts totalling $483,350 were owed to him by various clients: His daughter, Mrs.
WALsH, J.:—The facts in this case are not in dispute. On February 1, 1958 appellant acquired, as a result of his efforts as a prospector with one Hutchison, a mining property known as the mining titles and interests in a miner’s certificate and
Jupson, J. (concurred in by Abbott and Ritchie, JJ.) :— During each of the years 1960 to 1965 inclusive, the respondent, William Panko, suppressed income in the total amount of $165,801.70. For this offence he was prosecuted under Section 132 of the Income Tax Act. Two informations were laid, one information containing a charge for each of the years 1960 to 1965 inclusive for having violated Section 132(1) (a), and the other information contained one charge for having violated Section 132(1) (d) for the period March 23, 1961 to June 30, 1966.
Kerr, J.:—This is an appeal by way of Special Case stated for the opinion of the Exchequer Court of Canada pursuant to its General Rules 150 and 151, and continued in the Federal Court of Canada, in respect of the appellant’s appeal from the
GIBSON, J.:—This is an appeal from an assessment for income tax for the taxation year 1966 by which the appellant’s claim for exemption from income in the amount of $2,960,950 was disallowed, which sum was income derived during the 1966 taxation year from
THURLOW, J.:—These appeals are from assessments of nonresident income tax levied in respect of amounts of interest remitted by City Park Apartments Limited, a resident Canadian corporation to each of the appellants in each of the years 1966, 1967 and 1968. In
GIBSON, J.:—This is an appeal from re-assessments of the appellant’s income for the taxation year 1966 whereby the appel- lant’s income was increased by an amount of $531,706.28, being made up of what was alleged to be a gain of $451,706.23 realized on
The Curer Justice (orally for the Court) :—It will not be necessary to hear counsel for the respondent.