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Stevenson & Hunt Insurance Brokers Ltd. v. The Queen, 93 DTC 5125, [1993] 1 CTC 383 (FCTD), briefly aff'd 98 DTC 6383 (FCA)-- summary under Paragraph 12(1)(b) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) Contingent profit commissions, which an insurance broker was entitled to receive from insurance companies in respect of its 1983 fiscal year and that were contingent on the insurance companies' profitability on policies sold by the broker, did not constitute amounts receivable by the broker at the end of that fiscal year given the impossibility of coming to a reasonable estimate of the amount of those commissions at the end of the fiscal year. ...

Day & Ross v. The Queen, 76 DTC 6433, [1976] CTC 707 (FCTD)-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) Insurance premiums were payable each year by the taxpayer pursuant to a Lloyds policy which established the premiums payable for each year in accordance with a formula which included "reserves, as estimated by the Insurers for outstanding losses, outstanding at the time of adjustment. ...

Cunard & Company Limited v. Canada (Attorney General), 2012 DTC 5122 [at at 7192], 2012 FC 683-- summary under Subsection 85(7.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(7.1) not unreasonable to not permit late-filing by dissolved corporation Scott J. found that the Barnabe Estate principle, which allowed elections to be made by the estate of a deceased person, did not apply to a late-filed election by a corporation that had been wound up. ...

Baine, Johnstone & Co. Ltd., 77 DTC 5394, [1977] CTC 556 (FCTD)-- summary under Goodwill, Trademarks and Customer Lists Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Abakhan & Associates Inc. v. Canada (Attorney General), 2008 DTC 6028, 2007 FC 1327-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) insufficient evidence of misrepresentation O'Reilly J. indicated that he saw nothing preventing a company from making a request for judicial review of a decision of the Minister not to accede to the corporation's request for a reassessment of a taxation year (preceding the normal reassessment period) in which the taxpayer allegedly had exaggerated its own taxable income. ...

Dominion Metal & Refining Works Ltd. v. The Queen, 86 DTC 6311, [1986] 2 CTC 47 (FCTD)-- summary under Land Summary Under Tax Topics- General Concepts- Fair Market Value- Land In 1976 an adjoining land owner ("Ogilvie") in need of expanding its facilities paid what was apparently a substantial premium over their open market price for lands of the taxpayer. ...

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291, [1991] 1 CTC 541 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).-- summary under Paragraph 20(1)(l) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(l) The taxpayer for tax and financial statements purposes claimed reserves for doubtful accounts which were significantly in excess of its actual bad debt write-offs for the following year in light of its policy of continuing to make sales to high risk and past due accounts rather than writing off such accounts. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus At the time of reassessing the taxpayer, Revenue Canada indicated that it regarded the taxpayer's interest in a property as having been acquired in exchange for services to be provided by the taxpayer. ...

Hanley & Co. Ltd. v. The Queen, 90 DTC 6354, [1990] 2 CTC 71 (FCTD)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...

Rudelier Ranches & Livestock Co. Ltd. v. The Queen, 89 DTC 5180, [1989] 1 CTC 417 (FCTD)-- summary under Real Estate Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ...