Search - 三河市 市委书记 现任

Janin & Compagnie Limitee v. Minister of National Revenue, [1971] CTC 158, 71 DTC 5116 DUMOULIN, J. ... Janin & Compagnie Limitée (the appellant), operating jointly as Canit Janin Joint Venture, jointly and severally undertook to build for Quebec Cartier Mining Company (Canadian subsidiary of United Steel of America), an inland port and allied structures, in conformity with plans and specifications, for an amount of $13,233,467.00. 2. ...

Hope Hardware & Building Supply Co. Ltd. v. Minister of National Revenue, [1967] CTC 120, 67 DTC 5085 SHEPPARD, D.J. ... That resulted in the agreement (Ex, 49) of December 9, 1959, between the Hope Hardware & Building Supply Co. ... This appellant, Hope Hardware & Building Supply Co. Ltd., contends that the timber sales in question were bought for the use of the partnership to be logged in future and not for the purpose of resale; that the timber licences were a capital asset, and that the sale to Pretty’s Limited was a sale of the business and not a sale in the course of the business and therefore not taxable. ...

Olympia Floor & Wall Tile (Quebec) Ltd. v. MNR, 70 DTC 6085, [1970] CTC 99 (FCTD) JACKETT, P. ... The decision of this Court in O’Reilly & Belanger, Limited v. M.N.R., [1928] Ex.C.R. 61; [1917-27] C.T.C. 332, is distinguishable from this case in that there was no evidence there, as there is here, with reference to the amounts over $100, of an immediate expectation of business as a result of making the payments. ... The appeal will be allowed with costs and the assessments under appeal will be referred back to the respondent for reassessment on the assumption that all the contributions in question that were over $100 are deductible in computing the appellant’s income for the appropriate year and that the remainder of such contributions are ‘‘gifts’’ within Section 27(1) (a) of the Income Tax Act. 1 *27. (1) For the purpose of computing the taxable income of a taxpayer for a taxation year, there may be deducted from the income for the year such of the following amounts as are applicable: (a) the aggregate of gifts made by the taxpayer in the year (and in the immediately preceding year, to the extent of the amount thereof that was not deductible under this Act in computing the taxable income of the taxpayer for that immediately pre ceding year) to charitable organizations in Canada exempt from tax under this Part by paragraph (e) of subsection (1) of section 62, corporations or trusts resident in Canada and exempt from tax under this Part by paragraph (f) or (g) of subsection (1) of section 62, housing corporations resident in Canada and exempt from tax under this Part by paragraph (ga) of subsection (1) of section 62, Her Majesty in right of the provinces and Canadian municipalities, not exceeding 10% of the income of the taxpayer for the year, if payment of the amounts given is proven by filing receipts with the Minister; 2 *In so far as the amounts that were not over $100 are concerned, I regard the reasoning of Vaisey, J. in Hutchinson & Co. ...

David $. Christie, Executor or the Estate or Charles S. Christie v. Minister of National Revenue, [1968] CTC 371, 68 DTC 5240 CATTANACH, J. ... Christie had in the estate of her father as remainderman subject to the life interest of her mother was an ‘‘interest in expectancy ‘ ‘ within the meaning of those words as they appear in Section 58(1) (s) (i) of the Estate Tax Act and as those words are defined in Section 58(1) (k) and that accordingly the Minister’s valuation of that interest for the purpose of assessment of Mrs. ...

Gordon $. Shipp, Harold G. Shipp, Bessie L. Shipp and June C. Shipp v. ... On March 4, 1959, Gordon $. Shipp, the father, called Harold G. Shipp on the telephone at San Juan and informed him that he and Bessie L. ...

The Calgary & Edmonton Corporation Limited v. Minister of National Revenue, [1955] CTC 161, 55 DTC 1099, [1955] CTC 160 FOURNIER, J. ...

The lawful heirs when they inherit, are seized by law alone of the property, rights and actions of the deceased, subject to the obligation of discharging all the liabilities of the succession. ’ ’ An old maxim inspiring the above text ‘‘Le mort saisit le vif’’, renders the heirs, testamentary or legal, the living ‘ ‘ continuers ’ ’ of the dead legator. ... One instance is conclusive, that found in the third paragraph of Article 918 of the Civil Code: ‘When duties are at an end, the testamentary executor must render an account to the heir or legatee, who receives the succession, and pay him over the balance remaining in his hands. ’ ’ Now, Article XI of the pension plan, intituled “Death Benefit’’, provides as follows: “XI. ... Since no factual difference nor legal distinction can be drawn between the collective expression ‘ ‘ estate ’ ’ and its physical specifi- cation, the heir or heirs, it does appear obvious that the expression ‘‘estate’’ in Article XI is not only indicative of an entity authorized to receive payment, but acknowledges also an ownership of and absolute right to such payment in the heirs of the late participant. ...

During the years 1957 to 1962, the appellant had a revenue each year from winning purses by racing his own horses as follows: 1957 — $ 2,470.00 3 to 4 horses 1958 — $ 5,645.00 4 to 5 horses 1959 — $ 8,565.00 4 to 5 horses 1960 — $28,562.14 20 horses 1961 — $20,340.60 8 to 10 horses 1962 — $21,660.00 3 to 4 horses During the same period, his revenues from boarding and training horses belonging to others were as follows: 1957 —nil 1958 — $ 1,600.00 (estimated) 2 horses 1959 — $ 1,635.00 3 to 4 horses 1960 — $ 1,638.00 8 to 4 horses 1961 — $16,547.03 20 horses 1962 — $26,598.60 20 to 25 horses Quite apart from these activities, which I will refer to as the appellant’s farming business, the appellant had a substantial source of income during the years 1959 to 1962 from activities which I will refer to as his real estate activities. ... The extent of the appellant’s revenue from his real estate activities appears from the following figures: 1959 — Commissions $36,436.28 — Profits nil 1960 — Commissions $ 9,000.00 — Profits $80,647.98 1961 — Commissions $32,722.08 — Profits $30,500.00 1962 — Commissions $37,349.32 — Profits nil No problem has arisen in connection with the appellant’s revenues from his real estate activities. ...

Le Ministre du Revenu national ajoutait aux profits déclarés par l’intimé pour les années 1957, 1958 et 1959, les montants ci-dessous: 1957 — $ 4,230 1958 — $ 6,918 1959 — $20,000 Ces ajoutés aux déclarations du Dr. ... It is extremely difficult to express, but it seems to me that people would say he is addicted to betting, and could not say that his vocation is betting. ’ ’ BETTING ON PERSONAL SKILL. ... Green. ’ ’ ’ PAR TOUS CES MOTIFS, la Cour confirme la décision de la Commission de l’impôt et rejette l’appel, avec allocation des dépens de Cour à l’intimé, après taxation. ...

Part VIII has the heading ‘‘ Health’’, and Section 1 thereof reads as follows: 1. ... Section 1 of Part VIII of Schedule III contains the words treatment ”, “ mitigation ”, “ prevention ”, “ disease ’ ’ and ‘ ab normal physical state’’. ... So your calorie bank is balanced”; ‘‘ Kat, drink and be merry with Christmas desserts made with Sucaryl’’; “You’re in if you’re thin—you’re out if you’re stout’’; ‘You have 3 months to get in shape for summer’’; ‘‘Let Sucaryl help hold your • calorie-line ’ ”; “ Diet or not—Suearyl helps hold your ‘calorie-line ”; “If you’re a regular sugar user, switch from sugar to Sucaryl and you’ll cut out 100’s of calories per day, without going on a diet’’; ‘‘People with a sweet tooth who have a weight problem, or who just want to keep in shape, are switching to Suearyl’’; ‘‘Suearyl is the product used to sweeten over 90% of the low-calorie food and beverage products sold through your stores”; “If you’re watching your weight—switch to Sucaryl”; “Sucaryl is the easy way to aid your diet efforts’’ “When your diet says ‘no sweets’—switch to Sucaryl’’; ‘ ‘ Sweeten with Sucaryl for low-calorie diets ”; ‘‘Most families have calorie-counters ’ ’. ...