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A & D Holdings Inc. v.The Queen, 2006 DTC 2219, 2005 TCC 768-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Property that the vendors sold to the taxpayer contained chromium and the vendors did clean up work until the problem of contamination in runoff water was resolved to the satisfaction of the City. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence parol evidence rule applied to Minister Campbell J. found that the parol evidence rule prevented the Minister from bringing extrinsic evidence that would have shown that the taxpayer was disingenuous in the way it characterized one of its business contracts for tax purposes. ...

On-Line Finance & Leasing Corporation v. Canada, 2010 DTC 1325 [at at 4243], 2010 TCC 475-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income The taxpayer's business was to facilitate B.C. municipalities in obtaining vehicles and equipment. ...

Fortin & Moreau Inc. v. The Queen, 90 DTC 1450, [1990] 1 CTC 2583 (TCC)-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership The Quebec taxpayer was found to have "acquired" trucks pursuant to leases given that it had possession and use of the trucks, it had assumed all risks, it had the option, six months before the expiry of the lease, to purchase the trucks for an amount approximately equal to the fair market value of the remaining lease payment, and it was required to pay the "rent" even if the trucks were destroyed or it no longer had the use of them. ...

Simmonds & Sons Ltd. v. MNR, 89 DTC 707, [1990] 1 CTC 2087 (TCC)-- summary under Subsection 17(1) Summary Under Tax Topics- Income Tax Act- Section 17- Subsection 17(1) Because a U.S. affiliate ("Dynacharge U.S. ...

Coopers & Lybrand Limitéé v. MNR, 94 D.T.C 1626, [1994] 2 CTC 2244 (TCC)-- summary under Subsection 153(1.3) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.3) 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). ...

Wacky Wheatley's TV & Stereo Ltd. v. MNR, 87 DTC 576, [1987] 2 CTC 2311 (TCC)-- summary under Start-Up and Close-Down Expenditures Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Les Placements A & N Robitaille Inc. v. MNR, 96 DTC 1062, [1996] 1 CTC 2141 (TCC)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital Archambault TCJ. found that a business of manufacturing or reconditioning and selling boats or other nautical products had goodwill that was not purely personal to the shareholder-manager of the corporate owner of the business given that, on the evidence, a sale of such business would have occurred for a purchase price in excess of the value of the tangible assets. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Eligible Capital Expenditure Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...

212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) Each taxpayer closed the purchase of a 10% interest in a resource property by giving the vendor an interest-bearing demand promissory note for $3.5 million. ...