Heald, J:—This is an appeal from the reassessment of the plaintiff by the defendant for the taxation year 1971 on the basis that the plaintiff was an officer or servant of Canada within the meaning of subparagraph 139(3)(c)(i) of the Income
Cattanach, J:—These are appeals from a judgment of the Tax Review Board, dated June 12, 1972 whereby appeals by the defendant herein from assessments to income tax for the defendant’s 1965, 1966, 1967 and 1968 taxation years were allowed.
Sheppard, DJ:—The issue is whether the payment of $30,000 to the appellant in the taxation year 1966 was a retiring allowance within subparagraph 6(1)(a)(v), as defined in paragraph 139(1)(aj) as alleged by the respondent, or is a capital allowance as
The Chief Justice (concurred in by St-Germain, DJ):—This is an appeal from a judgment of the Trial Division dismissing, with costs in the cause, an application that, in its inception, was a motion for leave to file a conditional appearance and a stay under
Gibson, J:—The appellant, a Canadian corporation, obtained certain intangible assets from The Rapids-Standard Company Inc, of Grand Rapids, Michigan, hereinafter called “the US company” by a so-called Deed of Gift, which assets the appellant, after acquisition, put a
Pratte, J:—This is an appeal from a reassessment of the plaintiff’s income tax for the 1966 taxation year. That reassessment was made on the basis that the plaintiff had improperly deducted from its income a capital outlay of $500,000.
The Chief Justice (ail concurring):—This is an appeal from a judgment of the Trial Division dismissing an appeal from a judgment of the Tax Appeal Board that dismissed an appeal from the appellant’s assessments under Part I of the Income
Collier, J:—This is an appeal by the taxpayer from the Tax Appeal Board. (now the Tax Review Board) which affirmed a reassessment by the respondent Minister for the 1963 taxation year. The respondent added to the appellant’s income the sums of $50,000. and
The Associate Chief Justice:—This is an appeal by Her Majesty the Queen from a decision of the Tax Review Board, dated February 22, 1972, allowing. the appeal by defendant, Compagnie Immobilière BCN Liée, from an income tax assessment dated
Bastin, DJ:—It was agreed that the trial of the action by Elmer T Carlson and that of Gordon E Carlson should be heard together. Both actions seek to recover a penalty imposed by the Minister of National Revenue for late filing of income
