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Goar, Allison & Associates Inc. v. The Queen, 2009 DTC 653, 2009 TCC 174 (Informal Procedure)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity After finding that the taxpayer was not liable to a penalty under s. 162(2.1) of the Act, C. ...

Bowes & Cocks Ltd. v. MNR, 89 DTC 341, [1989] 2 CTC 2043 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) The taxpayer used borrowed money to acquire additional shares of its subsidiary, which the taxpayer immediately wound-up in the process of which a piece of rural land (the subsidiary's only significant asset) was conveyed to the taxpayer. ...

Richter & Associates Inc v. The Queen, 2005 TCC 92-- summary under Subsection 141.01(5) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(5) allocation between own suit and litigation support The allocation of substantially all the litigation-related costs of a trustee in bankruptcy to its "litigation support business" of supporting of a negligence suit for $800 million brought by the bankrupt company's creditors against the company's former auditors rather than to its action on behalf of the estate for $40 million for breach of contract, was found to be "fair and reasonable" in compliance with s. 141.01(5). ...

Hurley Mining Equipment & Services Inc. v. MNR, 89 DTC 403, [1989] 2 CTC 2101 (TCC)-- summary under Active Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Active Business Interest income which the corporate taxpayer, which was in the business of selling and servicing equipment used in the mining industry, earned on term deposits was held to be active business income. ...

Coopers & Lybrand Limitéé v. MNR, 94 D.T.C 1626, [1994] 2 CTC 2244 (TCC)-- summary under Remuneration Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(1)- Remuneration The appellant took possession on November 4, 1981 of the business of a debtor and, with the banks' authorization, paid the net amount of the employees' back wages pursuant to the usual payroll procedures of the debtor (including the preparation of payroll slips showing the deduction of source deductions). ...

Muir Cap & Regalia Limited v. Minister of National Revenue, 91 DTC 533, [1991] 1 CTC 2342 (TCC)-- summary under Income of the Corporation for the Year From an Active Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Income of the Corporation for the Year From an Active Business The holding by the taxpayer of substantial term deposits for the future purchase of business premises was "only a collateral purpose... and the withdrawal of the fund would not have 'a decidedly destabilizing effect' on the taxpayer's operations" (p. 536). ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Res Judicata Summary Under Tax Topics- General Concepts- Res Judicata Rip TCJ. found (at p. 1266) that "where the parties to the litigation are different there is no res judicata, even when the facts are identical". ...

Francis & Associates v. The Queen, 2014 DTC 1146 [at at 3468], 2014 TCC 137 (Informal Procedure)-- 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) taxpayers held to standard of wise and prudent law partner A review of a law firm's accounts in 2005 by its external accountant revealed various substantial errors for the 2002 to 2004 years. ...

Toronto Refiners & Smelters Ltd. v. The Queen, 2001 DTC 876 (TCC), aff'd 2003 DTC 5002, 2002 FCA 476-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base The taxpayer agreed to transfer its Toronto property to the City of Toronto with the compensation to be determined (under section 31 of the Expropriations Act) by the Ontario Municipal Board. ...

The Humber College Institute of Technology & Advanced Learning v. ...