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FCTD

Nesbitt v. The Queen, 96 DTC 6045, [1996] 1 CTC 282 (FCTD)

.: The Plaintiff herein filed a Statement of Claim in which he appealed Notice of Reassessment No. 1911903, dated July 13, 1989 (the “Second Reassessment”) in respect of his 1981 taxation year. ...
FCTD

Itt Industries of Canada Ltd. v. R., 99 DTC 5105, [1999] 2 CTC 277 (FCTD), aff'd 2000 DTC 6445, Docket: A-99-99

It is noteworthy that the first line of text in the Notice states that “... it is expedient to amend the Income Tax Act and to provide among other things...” ...
FCTD

Owen Holdings Ltd. v. R., 97 DTC 5401, [1997] 3 C.T.C. 351 (FCA)

Holmested & Watson, in Ontario Civil Procedure note in their commentary on Rule 31.06(1), which, as noted above, also uses the phrase “relating to”: While clearly irrelevant matters may not be inquired into, relevancy must be determined by the pleadings construed with fair latitude. ...
FCTD

Dagenais v. The Queen, 95 DTC 5318, [1995] 2 CTC 100 (FCTD)

The plaintiffs received the following amounts as benefits under the plans: 1986 1987 1988 Dagenais $4,297.32 $10,166.28 $18,487.30 Halwachs N/A $13,852.72 N/A York N/A $ 2,092.80 N/A Paragraphs 6(1)(a) and 6(1)(f) of the Income Tax Act are the relevant statutory provisions in this appeal. ...
FCTD

Prior v. The Queen, 88 DTC 6207, [1988] 1 CTC 241 (FCTD), aff'd 89 DTC 5503 (FCA)

Valeo, supra, at p. 669 ”... every appropriation made by Congress uses public money in a manner to which some taxpayers object”. ...
FCTD

Greenbranch Investments Ltd. v. The Queen, 80 DTC 6384, [1980] CTC 514 (FCTD)

S & S Properties Limited v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294 at 419 [6298] where Walsh, J in quoting from Roy M Powers Her Majesty the Queen, [1975] CTC 580; 75 DTC 5388 and the judgment of Addy, J therein states: Yet, one cannot say that, as a matter of law, every land developer is precluded from establishing that in a particular case there was no primary or secondary intention to speculate anymore than in a case such as the one at Bar where a mature man has never previously resold a piece of real estate at a profit, is one precluded from finding that, on his very first venture in this sphere, he did in fact have the intention of reselling at a profit when he originally purchased the lands. ...
FCTD

Marotta v. The Queen, 86 DTC 6192, [1986] 1 CTC 393 (FCTD)

Michael’s carried with it an appointment to the University Dr. Marotta became a lecturer. ...
FCTD

Range Grain Co. v. R., 97 DTC 5221, [1997] 2 CTC 227 (FCTD)

Coopers & Lybrand Limited, supra, at page 6547, as follows: In Crown Tire, Strayer was required to construe the phrase as it is used in paragraph 125.1(3)(a) of the Act. ...
FCTD

The Queen v. Twigg, 96 DTC 6297, [1996] 3 CTC 135 (FCTD)

.: This is an appeal by way of trial de novo from a decision of the Tax Court of Canada, dated April 5, 1991, which allowed the defendant’s appeal from reassessments for the taxation years 1980, 1981, 1982, 1983, 1984, and 1985. ...
FCTD

Aluminium Co. of Canada Ltd. v. The Queen, 74 DTC 6408, [1974] CTC 471 (FCTD)

The plaintiff’s assessment for the taxation year 1966 will be referred back to the Minister for reassessment not inconsistent with these Reasons. 1 See: Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] CTC 99; 70 DTC 6085, and Pigott Investments v The Queen (supra). ...

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