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., 98 DTC 1416, [1998] 2 C.T.C. 2712 (TCC)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) A lump sum payment made to the taxpayer by her disability insurer in settlement of her claim for long-term disability benefits was not taxable to her given that the premiums paid by her employer had been included in her income. ...

MNR, 93 DTC 14, [1992] 2 CTC 2764 (TCC)-- summary under Dividend Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Dividend The purported payment of a dividend was ineffective because payment of a dividend would have impaired the capital of the corporation contrary to the provisions of the Alberta Companies Act. ...

MNR, 90 DTC 1917, [1990] 2 CTC 2466 (TCC)-- summary under Subsection 39(4) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(4) The Minister was not compelled to accept an s. 39(4) election in an amended return which the taxpayer filed four years after the taxation year in question. ...

., 97 DTC 1156, [1997] 2 CTC 2960 (TCC)-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning Lamarre TCJ. found that evidence of usage within the oil and gas industry of "discovery" and "accumulation" would assist in interpreting those words as used in the Act. ...

The Queen, 95 D.T.C 5337, [1996] 2 CTC 18 (FCA)-- summary under Subsection 166.2(1) Summary Under Tax Topics- Income Tax Act- Section 166.2- Subsection 166.2(1) The Tax Court judge did not err in quashing an application for extension of time to file a Notice of Objection. ...

The Queen, 95 D.T.C 5337, [1996] 2 CTC 18 (FCA)-- summary under Subsection 244(15) Summary Under Tax Topics- Income Tax Act- Section 244- Subsection 244(15) The taxpayer had failed to rebut the presumption of due issuance created by s. 244(15) by any evidence to the contrary. ...

The Queen, 95 DTC 591, [1995] 2 CTC 2133 (TCC)-- summary under Estoppel Summary Under Tax Topics- General Concepts- Estoppel The doctrine of promissory estoppel was found to be inapplicable to supposed agreements of the Minister not to assess penalties and interest, as well as to the taxes themselves. ...

MNR, 90 DTC 1854, [1990] 2 CTC 2417 (TCC)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) non-payment of interest not a loan The non-payment of interest did not constitute the "making of a loan" for purposes of the pre-1982 version of the provision, although it resulted in the shareholder "becoming indebted" to the corporation within the meaning of s. 15(2) for 1982 and subsequent taxation years. ...

MNR, 91 DTC 413, [1991] 2 CTC 2622 (TCC)-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing Lease inducement payments, which the taxpayer received on income account, were required to be included in full in the year of receipt rather than being amortized over the term of the leases, given that the taxpayer deducted all its fitting-out costs in the year of receipt. ...

MNR, 91 DTC 699, [1991] 2 CTC 2045 (TCC)-- summary under Retiring Allowance Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance The taxpayer, who was laid off by his employer and filed a grievance under the collective agreement, received an award from the arbitrator as a retiring allowance. ...