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TCC
Lars Eric Larsson v. Her Majesty the Queen, [1996] 3 CTC 2430, [1998] DTC 2213 (Informal Procedure)
.: — These appeals were‘heard in Penticton, British Columbia on June 12, 1996. ...
TCC
Allarcom Pay Television Limited v. Her Majesty the Queen, [1996] 3 CTC 2608, 97 DTC 1558
. /?. [8] for the proposition that the word “goods” in section 125.1 “is used in the common parlance of merchandise or wares, or, to put it in legal jargon, tangible, movable... property”. ...
TCC
Robert E. Angus v. Her Majesty the Queen, [1996] 3 CTC 2618, 96 DTC 1823
(hereinafter “Punters”) and the Appellant was responsible for administering Punters account; (c) The Appellant became involved with the principals of Punters, purchased shares in the corporation, assisted in issuing press releases, introduced potential investors to Punters and attended directors’ meetings; (d) The Appellant acquired and disposed of shares in Punters as detailed in schedule “A” attached hereto and his gains were in the following amounts: 1986: $129,573 1987: $46,731 1988: $ 17,125 (e) The shares acquired by the Appellant in January and March 1986 were acquired on the open market, the purchase price having been paid in cash; (f) The 100,000 shares acquired by the Appellant in June of 1986 were received from Robert Freeland for no cost as they represented a payment for services rendered (Robert Freeland was a venture capitalist and an important source of capital for Punters); (g) At all relevant times the Appellant’s intention was to profit from trading in Punters shares and at no time did he acquire or hold shares in Punters as an investment on account of capital. ...
TCC
Giulio Magliocchetti v. Her Majesty the Queen, [1996] 3 CTC 2660 (Informal Procedure)
.: — This appeal is from reassessments of the taxpayer for the 1991 and 1992 taxation years, notices of which were allegedly mailed to the Appellant on May 6, 1994, in which the Minister disallowed the deduction of rental losses, carrying charges and expenses. ...
TCC
Latsay v. R., [1997] 2 CTC 2125
. … For resuming the male role, I should be treated equally and given the same male deduction of ITA sec 60(b). ...
TCC
Foulds v. R., [1997] 2 CTC 2660
Subparagraph 56(l)(n)(i) states: (/) The aggregate of all amounts (other than amounts described in paragraph q), amounts received in the course of business, and amounts received in respect of, in the course of or by virtue of an office or employment) received by him in the year, each of which is an amount received by the taxpayer as or on account of a scholarship, fellowship or bursary, or a prize for achievement in a field of endeavour ordinarily carried on by the taxpayer other than a prescribed prize),... ...
TCC
Barker v. R., [1998] 1 CTC 2538
Dukelow and Betsy Nuse, in part as follows: “Pecuniary support including support or alimony to be paid to someone who is not a spouse. [...] ...
TCC
Yakubu v. R., [1998] 1 CTC 2649
Attached to the letter is a single sheet of paper entitled ‘Appraisal for Parkland Savings & Credit Union’. ...
TCC
Lannuzzi v. R., [1998] 1 CTC 2671, 98 DTC 1278
The assessments impose upon the Appellants the outstanding liability of the various companies for source deductions made by the companies from their employees for income tax, both federal and provincial, and for contributions under the Unemployment Insurance Act (as it then was called), and the Canada Pension Plan, together with penalties and interest. [1] The assessments in question are as follows: Company Assessment date Amount for Daniel lan nuzzi Daisons January 20, 1993 $175,245.15 Corcan January 20, 1993 $575,012.97 Fotoset January 20, 1993 $302,848.10 VitaSana January 20, 1993 $ 52,302.75 for Elena Caprile Daisons January 20, 1993 $175,245.15 Corcan September 21, 1994 $657,093.51 By agreement of the parties, the six appeals were heard together on common evidence. ...
TCC
Barker v. R., [1998] 1 CTC 3059
Dukelow and Betsy Nuse, in part as follows: “Pecuniary support including support or alimony to be paid to someone who is not a spouse. [...] ...