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212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC) Rip J.T.C.C. — The main issue in these appeals [1] is whether a certain outlay is an expense incurred in the course of carrying on a business and is deductible in determining the appellants’ income from business for the year in accordance with section 9 of the Income Tax Act (“Act”). The facts in the appeals of 212535 Oil & Gas Ltd., 212634 Oil & Gas Ltd., 212873 Oil & Gas Ltd. and 228262 Alberta Ltd. from income tax assessment for their 1981 taxation year [2] are similar, if not identical, to those in the appeal of St. ... Ives, supra, was whether the sum of $1,250,000 which that taxpayer had agreed to pay Carter Oil & Gas Ltd. ...

K & D Logging Ltd. v. The King, 2023 TCC 23 Docket: 2017-4536(IT)G BETWEEN: K&D LOGGING LTD., Appellant, and HIS MAJESTY THE KING, Respondent.   ... APPENDIX   Relevant Statutory Provisions:   CITATION: 2023 TCC 23 COURT FILE NO.: 2017-4536(IT)G STYLE OF CAUSE: K & D LOGGING LTD. ... Quo Vadis   Firm: Koffman Kalef For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   [1] C. ...

A-Supreme Nursing & Home Care Services Inc. v. The King, 2023 TCC 39 Docket: 2017-689(GST)G BETWEEN: A-SUPREME NURSING & HOME CARE SERVICES INC., Appellant, and HIS MAJESTY THE KING, Respondent.   ... FACTS [1] A-Supreme Nursing & Home Care Services Inc. (the Appellant) places nurses in long-term care facilities and nursing homes (the “Clients”). ... (the “Act ”). B. Background: [4] The Appellant is incorporated under the Business Corporations Act of Ontario, with its head office located in Toronto, Ontario. ...

Dew Engineering & Development Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2904 O’Connor J.T.C.C.: — This appeal was heard at Ottawa, Ontario, on August 6, 1996 pursuant to the General Procedure of this Court. ... IT-79R3 provides: Meaning of “Building ” and “Structure ” 1. “Building” is a term of wide range covering any structure with walls and a roof affording protection and shelter. ... There is an argument to be made that section 37 is required to allow SR & ED costs to be deducted. ...

They are: (a) the existence of a common mind which directs the bargaining for both parties to the transaction, (b) parties to a transaction acting in concert without separate interests, and (c) " de facto " control. ... " [31] This approach was also adopted by Cullen, J. in the case of Peter Cundill & Associates Ltd. v. ... Part 2 – Review of the Evidence as it relates to Kevin Sharp and Brian Sharp [88] I do not propose to review all of the evidence a further time. ...

Fleming & Co. (Machinery), Ltd. (1951), 33 T.C. 57 (Ct. of Sess.). 0997_5941_6143 3 See e.g., The Glenboig Union Five Clay Co., Ltd. v. Commissioners of Inland Revenue (1922), 12 T.C. 427 (H. of L.) at 39-40; Barr, Crombie & Co., Ltd. v. ... See Barr, Crombie & Co., Ltd. v. C.I.R., [1945] S.C. 271; 26 T.C. 406 at 411 (Scot.), Fleming, supra, at page 63. ...

& M. Johnson Contracting Ltd. v. The Queen, docket 96-4072-IT-G Date: 19980515 Docket: 96-4072-IT-G BETWEEN: A. & M. JOHNSON CONTRACTING LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Subsection 152(6) seems to impose some obligation on the Minister because the operative clause begins with the words “the Minister shall reassess... ”. ...

BUREAU BARRISTER & SOLICITOR INCORPORATED, Applicant, and HER MAJESTY THE QUEEN, Respondent.   ... Except as otherwise indicated, statutory references herein are provisions of the ETA. [2]   Under the marginal heading, “When order to be made”, subsection 305(5) provides: (5)   No order shall be made under this section unless (a)   the application is made within one year after the expiration of the time otherwise limited by this Part for appealing; and (b)   the person demonstrates that (i)   within the time otherwise limited by this Part for appealing, (A)   the person was unable to act or to give a mandate to act in the person’s name, or (B)   the person had a bona fide intention to appeal, (ii)   given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application, (iii)   the application was made as soon as circumstances permitted it to be made, and (iv)   there are reasonable grounds for appealing from the assessment. [3]   The respondent asserts that the following four requirements specified in subsection 305(5) were unmet: subparagraph 305(5)(b)(i) – the applicant must demonstrate that within the 90-day period for appealing … it had a bona fide intention to appeal; subparagraph 305(5)(b)(ii) – given the reasons set out in the application and the circumstances of the case, it would be just and equitable to grant the application; subparagraph 305(5)(b)(iii) – the application was made as soon as circumstances permitted; and subparagraph 305(5)(b)(iv) – there are reasonable grounds for appealing … Factual overview: [4]   At the hearing, an amended affidavit of Canada Revenue Agency (CRA) officer S.  ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Paragraph 12 refers to — and I quote — Lou Lokash Limited received a benefit or advantage in the amount of $50,000 from Lou Lokash & Associates Limited which amount is included in computing the income of Lou Lokash Limited, a shareholder, pursuant to subsection 15.1 of the Income Tax Act. ... They had only the word of Lou Lokash that they held a proportionate interest in such a mortgage — indirectly through the corporation Lou Lokash & Associates, but they held nothing directly in the mortgage as such. ... What they had was simply their confidence in the organization “Lou Lokash & Associates” — in fact in Lou Lakash personally, if one would care to put it on that basis. ...

L & K Farms Ltd. v. The Queen, docket 98-570-IT-G Date: 19990903 Docket: 98-570-IT-G BETWEEN: L & K FARMS LTD., Appellant, and HER MAJESTY THE QUEEN, Respondent. ... L & K ordered a special tractor powered by a Cummins Diesel engine, which was L & K's choice. ... Even if serial number D-100035 was not inserted into L & K's copy of Form A on December 29, 1993, the goods then passed to L & K. ...