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COURT FILE NO.:                                                 2000-3982(EI) and 2000-3984(CPP) STYLE OF CAUSE:                                               Sara Consulting & Promotions Inc. v.                                                                                 ... Bell DATE OF JUDGMENT:                                       November 20, 2001 APPEARANCES: Counsel for the Appellant:                  Carman P. McNary Counsel for the Respondent:              Margaret McCabe COUNSEL OF RECORD: For the Appellant:                 Name:                Carman P. ...

Rip" J.T.C.C. [1]               85 DTC 568. [2]               [1971] Tax A.B.C. 717, 71 DTC 476. [3]               66 DTC 714, 42 Tax A.B.C. 174. [4]               Paragraph 18(1)(a) of the Act. [5]               Section 67 of the Act. [6]               R.S.C. 1927, c. 97. ... Electric, supra at 1028. [23]             (1957), 57 DTC 1055 at 1062. [24]             (1947), 3 DTC 1090. [25]             Edwin C. ... In any event Iacobucci J. rejected that argument. [27]             [1988] 2 S.C.R. 175 at 189. [28]             Symes, supra at 6014. [29]             Ibid. [30]             See R. v. ...

R & S Industries Inc. v. The Queen, 2017 TCC 75 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.     ... Costs of the motion shall be in the cause.   The Respondent shall file a reply on or before June 30, 2017.   ... Graham” Graham J.   Citation: 2017 TCC 75 Date: 20170505 Docket: 2014-3997(IT)G BETWEEN: R & S INDUSTRIES INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ...

Trew Security & Communication Ltd. v. M.N.R., docket 97-1887-UI Date: 19991026 Dockets: 97-1887-UI; 97-195-CPP; 97-2084-UI; 97-218-CPP; 97-2085-UI; 97-219-CPP; BETWEEN: TREW SECURITY AND COMMUNICATIONS LTD., PATRICIA WALLACE, DOUGLAS WALLACE, Appellants, and THE MINISTER OF NATIONAL REVENUE, Respondent, Reasons for Judgment MacLatchy, D.J.T.C.C. [1] These appeals were heard on common evidence at Toronto, Ontario on July 8, 1999. [2] The opening statements of these appeals clarified the positions of the parties. [3] The Respondent conceded that the appeals filed by Douglas Wallace and Patricia Wallace for unemployment insurance purposes should be allowed as both Douglas and Patricia Wallace were at all relevant times owners and each controlled more than 40% of the voting shares of Trew Security and Communications Ltd., the Payor. The Appellants were not engaged in insurable employment within the meaning of the Unemployment Insurance Act (the " Act ") and Employment Insurance Act (the " Amended Act ") for the 1995 taxation year as each Appellant controlled more than 40% of the voting shares of the Payor with the result that the employment was excepted by paragraph 3(2)(d) of the Act and paragraph 5(2)(b) of the Amended Act. [4] No amount of the unemployment insurance premiums or employment insurance premiums assessed the Payor relate to the employment of either Patricia or Douglas Wallace as it was determined above that their employment with the Payor during both 1995 and 1996 taxation years was not insurable employment. [5] The Payor applied to the Respondent for reconsideration of the assessments of October 16, 1996. [6] By letter dated September 10, 1997, the Respondent informed the Payor that it had been determined that the Payor's workers (Robbie Robert Wallace and Wayne Hilts) were employed pursuant to a contract of service and, accordingly, the Respondent confirmed the assessments of October 16, 1996. [7] In making his decision, the Respondent relied on the following facts set out in paragraph 11 of the Amended Reply to the Notice of Appeal in the case of Trew Security and Communications Ltd. (97-1887(UI)): "(a) the Appellant is an incorporated business of which, at all material times, Douglas Wallace and Patricia Wallace were shareholders; (b) Patricia and Douglas Wallace are married to each other; (c) the Appellant operates a small service business involved in the installation of burglar and fire alarms, central vac, television and telephone systems and intercoms in personal residences; (d) during the 1995 taxation year, Patricia and Douglas Wallace were severally paid by cheque the amount of $36,000.00 as management fees; (e) at all relevant times, Douglas Wallace owned and controlled more than 40% of the voting shares of the Appellant; (f) the Appellant engaged Robbie Wallace and Wayne Hilts as workers (the "Workers"); (g) the Workers were employed by the Appellant pursuant to contracts of service. ... Although called a "management fee", such payment really constituted pensionable employment and within the meaning of subsection 27(5) and paragraph 6(1)(a) of the Canada Pension Plan (the " Plan ") as amended. ...

Each case stands on its own merits. [5]      In making his decision, the Minister relied on the following assumptions of fact: [TRANSLATION] (a)         The appellant was incorporated on July 1, 1995, as a result of a merger between Groupe Desmarais Inc. and Assurances Pinsonneault, Avard, Paré Inc.; (b)         The appellant's capital stock is distributed as follows:            - Gestion A.C.D. Inc. holds 60% of the voting shares;            - Yvon Pinsonneault holds 20% of the said shares; and            - Martin Avard holds 20% of the said shares; (c)         The capital stock of Gestion A.C.D. ... Watson Appearances Counsel for the Appellant:                             Rock Guertin Counsel for the Respondent:                         Dany Leduc JUDGMENT           The appeal is allowed and the Minister's decision vacated in accordance with the attached Reasons for Judgment. ...

La Ronge Lumber & Electric LTD v. Minister of National Revenue, [1985] 2 CTC 2271, 85 DTC 573 Sarchuk, TCJ:—The appeal of La Ronge Lumber & Electric Ltd (La Ronge) relates to an assessment by the Minister of National Revenue of penalty and interest on the appellant’s income tax liability for its 1981 taxation year. ... Mr Garrison responded by letter dated November 18, 1981 in the following words: We have completed the necessary arrangement with the Bank of Montreal, La Ronge, for Guarantees as follows: Edwin Elton Tubman — $21,874.22 La Ronge Lumber & Electric Ltd. — 16,466.76 The latter amount is $7,000.00 more than required. ... It is well settled law that “... When a debtor is making a payment to his creditor he may appropriate the money as he pleases, and the creditor must apply it accordingly. ...

Dock Edge + Inc. v. The Queen, 2019 TCC 11 Docket: 2016-539(IT)G BETWEEN: DOCK EDGE + INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Russell” Russell J.   Citation: 2019TCC11 Date: 20190116 Docket: 2016-539(IT)G BETWEEN: DOCK EDGE + INC., Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

Hughes & Co. Holdings Ltd. v. Minister of National Revenue, [1990] 1 CTC 2013, 89 DTC 702 Taylor, T.C.J. ... The notice of appeal deals with the unusual matter in a clear way: Hughes & Co. ... Hughes, as a director was counted, to meet the provisions of the section at issue — "... the corporation employs in the business throughout the year more than five full-time employees, — ". ...

& F. and Sumas, dated April 16, 1981. Exhibit A-6 — Form letter from M. ... & F. The "distribution rights’ applied to a larger area — all of Canada — and indeed export markets (see Exhibit A-5). ... & F., so that M. & F. had no further involvement with that company. ...

Appeal of R & L Investments Ltd. These are the matters in dispute regarding R & L Investments Ltd. ... The allocation of the $19,008.66 to taxation years is 1981 — $6,892.08, 1982 — $6,400.37 and 1983 — $5,716.21. ... The selling broker was Murdock & Maber Agencies Ltd. and it issued a receipt for $5,800 to R & L. ...