Heald, J:—This is an appeal by the plaintiff from its income tax assessment by the defendant for its 1971 taxation year. At issue, in these proceedings, is the nature of a payment made by the plaintiff in the sum of $150,000. The plaintiff contends that
Sweet, D.J.:—The plaintiff was incorporated under the laws of Ontario by letters patent dated November 13, 1964. Included in its objects is:
Heald, J:—This is an appeal by the plaintiff from a judgment of the Tax Review Board dismissing plaintiff’s appeal from the defendant’s assessment of plaintiff’s income tax return for the taxation year 1967. In issue in these proceedings is the propriety
Kerr, J:—This is in respect of an application pursuant to paragraph 174(3)(b) of the Income Tax Act. I am informed that it is the first application under that section of the Act, and that there is no jurisprudence relating
Walsh, J:—This is an appeal from an assessment dated December 20, 1968 wherein a tax in the amount of $109,050 plus $9,080 was levied in respect of the estate tax of the appellant. Appellant’s appeal against the assessment to the Tax Review Board was
The Associate Chief Justice:—An appeal is brought from the decision of the Tax Review Board of April 28, 1972, allowing appellant’s appeal from an assessment by the Minister for 1966, by which the latter rejected an amount of $115,369.33 which the company claimed
Walsh, J:—These proceedings are based on a reassessment of defendant’s income for 1967 as a result of which additional tax of $222.19 was assessed. Defendant opposed this, the reassessment was confirmed and defendant appealed to the Tax Review Board, where
Urie, J:—These are appeals by way of trial de novo by the plaintiffs from a decision of the Tax Review Board rendered on February 16, 1972 affirming assessments made by the defendant against them in respect of income earned by
Cattanach, J:—This is an appeal from a decision of the Tax Appeal Board, dated May 21, 1971, whereby the assessment of the appellant by the Minister to income tax for its 1967 taxation year was confirmed.
Sheppard, DJ:—The issue is whether the profit realized by the plaintiff on the resale of property was a capital gain on an investment as the plaintiff contends, or was business income as the Minister of National Revenue contends.
