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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     ...

For the various financial years of the company ending on January 31 and for the financial years of the appellant shareholder, the expenses in dispute are given below: Appellant company Appellant shareholder 1966 $ 1,210.00 1966 $ 7,565.05 1967 $ 6,965.05 1967 $11,200.55 1968 $13,758.17 1968 $10,869.66 1969 $11,361.51 1969 $10,231.30 1970 $10,231.30 1970 $ 9,346.01 1971 $14,119.92 1971 $ 4,050.18 1972 $ 6,087.00 $57,645.95 $59,349.75 less 8,125.85 less 11,387.82 (see par 3.02.2) (see par 3.02.1 (a) and (b)) $49,520.10 $47,961.93 4.04 This table, which was compiled from the ledgers and vouchers of the appellant company, contains sixty-three items in amounts varying from $65 to $3,960.53, which vary in kind from the keeping of horses to the purchase of an organ and include the purchase of a fur coat, purchase of a tractor and construction of a clubhouse on a farm. ... The appellant shareholder admitted this fact (TS 1 p 51). 4.05.5 The expenses paid by the appellant company for the farm consist of the labour of carpenters, labour of a regular employee, construction wood and the purchase of machinery: Total expenses including purchase of machinery 1966 $ 610.00 1967 $1,783.89 $ 590.00 1968 $2,263.27 “Nil” 1969 $5,518.41 $1,160.00 1970 $3,088.78 $2,804.46 1971 $6,761.80 $1,300.00 1972 $3,927.00 $3,927.00 $9,781.46 4.05.6 The expenses for wood, labour and repairs on the farm may be broken down as follows: 1967 Plumbing $ 124.38 Wood and repairs 355.39 Wood 94.45 Wood 1,177.46 Repairs 176.25 Repairs 443.42 $2,371.35 1968 Labour $ 624.38 Wood 137.67 Labour 467.68 Wood 65.00 Wood 550.89 Labour 1,075.50 $2,921.12 1969 Wood (/ of $907.15) $ 403.58 1970 Labour $ 284.32 1971 Labour $ 640.00 Wood (/ of $829.95) 415.00 Labour 1,078.25 Labour 2,401.47 $ 5,222.62 $10,515,09 4.05.7 The other expenses claimed with respect to the farm are the following: (a) labour of the groom, Mr Ricard, who was paid $3,960.53 in 1968 and $3,334.26 in 1969; (b) medical expenses of the daughter of a farmhand, $117.00 in 1969; (c) repair of electric cables broken by visitors, $624 in 1968 and $969 in 1969; (d) boarding of farm horses (the Legardeur firm), $610 in 1966. 4.06 Expenditure on residence It was also admitted that in 1967 a sum of $1,261.97 was paid by the appellant company for wood used to repair the appellant shareholder’s residence (TS 1 pp 74 and 75). 4.07 Cocktail party and meal expenditures 4.07.1 The appellant explained (TS 1 p 53) that in 1966, following an important political appointment of a friend who had, moreover, introduced him to many customers, he gave a cocktail party (with snacks). ... Year Penalties Tax payable 1966 $ 311.84 $ 1,247.35 1967 516.06 2,064.22 1968 582.19 2,328.77 1969 600.52 2,402.07 1970 546.07 2,184.28 1971 190.56 762.25 1972 412.40 1,649.60 $3,159.64 $12,638.54 B. ...

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, — ". ...

Unnamed persons Personnes non désignées nommément (2) The Minister shall not impose on any person (in this section referred to as a “third party”) a requirement under subsection 231.2(1) to provide information or any document relating to one or more unnamed persons unless the Minister first obtains the authorization of a judge under subsection 231.2(3). (2) Le ministre ne peut exiger de quiconque — appelé « tiers » au présent article — la fourniture de renseignements ou production de documents prévue au paragraphe (1) concernant une ou plusieurs personnes non désignées nommément, sans y être au préalable autorisé par un juge en vertu du paragraphe (3). ... FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-917-21   STYLE OF CAUSE: AKME POULTRY, BUTTER & EGGS DISTRIBUTORS INC v MINISTER OF PUBLIC SAFETY AND EMERGENCY PREPAREDNESS   PLACE OF HEARING: OTTAWA, ONTARIO   DATE OF HEARING: FEBRUARY 8, 2023   JUDGMENT AND REASONS: PAMEL J.   DATED: october 13, 2023   APPEARANCES: Erin E. Brown Jean-Simon Schoenholz Alexander Carden   For The Applicant Sarom Bahk Jessica Pizzoli For The Respondent SOLICITORS OF RECORD: Norton Rose Fulbright Canada LLP Ottawa, Ontario   For The Applicant Attorney General of Canada Montreal, Quebec   For The Respondent   ...

Joseph $. Irwin v. Minister of National Revenue, [1962] CTC 572 Noel, J. ... Ch. 748, to the effect that the word ‘ from ’ ’ may mean either inclusive or exclusive accord- ing to the context and subject matter and Canadian Fina Oil Limited v. ... Justice Day stated: “... as regards time, the word ‘from’ is akin to ‘after’ and excludes the day fixed for commencement of the computation. ’ ’ In Brown v. ...

& 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. ...

Tusket Sales & Service Limited v. The Queen, docket 1999-5124(GST)I (Informal Procedure) Date: 20000727 Docket: 1999-5124-GST-I BETWEEN: TUSKET SALES & SERVICE LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent. Reasons for Judgment Hamlyn, J.T.C.C. [1]            This is an appeal with respect to an assessment under Part IX of the Excise Tax Act (the " Act ") for the period January 1, 1993 to February 29, 1996, by Notice of Assessment No. 01CB0202152 dated July 17, 1996. [2]            The Appellant is a corporation involved in the sale of new and used motor vehicles. [3]            Between 1994 and 1995, the Appellant sold 14 vehicles to one Vaughn Pictou ("Pictou"), a status Indian. ... Pictou indicating that GST was paid; 6(i)           at no time did Mr. ...

Army & Navy Department Store Limited v. Minister of National Revenue, [1952] CTC 273, 52 DTC 1169, [1952] DTC 1168 ARCHIBALD, J. ... This statement is as follows: ‘ ‘ There are three companies involved in these proceedings, namely, Army & Navy Department Store (Western) Limited (hereinafter referred to as the ‘Western company’); Army & Navy Department Store Limited (hereinafter referred to as the ‘Alberta company’) and Army & Navy Department Store Limited (hereinafter referred to as the ‘Saskatchewan company’). ... Cohen) (2) The Alberta company—the shareholders are— 50 % to H. R. Cohen 10% to S. ...

& Co. Ltd. v. Minister of National Revenue, [1957] CTC 190 THURLOW, J. ... ‘ ‘ The way in which the Lord Justice Clerk applied the test is also of interest. ... " Unies you can get something worthwhile on the Drury Inlet timber, either on a lump sum or with a worthwhile deposit held so that it cannot be manipulated like the McNaughton one, we will let this timber stand hoping that prices will pick up in a reasonable period. ‘ ‘ Yours truly, • • GILLIES BROS. ...