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T Rev B decision

Charles N Gowen v. Minister of National Revenue, [1980] CTC 2188, 80 DTC 1176

Land $48,000 Add Improvement value at depreciated cost $ 9,000 Overall value by Market Approach $57,000 Development Approach $40,750 Income Approach $47,000 The overall value by the Market Approach is $57,000, which is based on actual land Sales which occurred nearby. ...
T Rev B decision

Jager Holdings (Calgary) Ltd, Jager Homes LTD v. Minister of National Revenue, [1980] CTC 2345, 80 DTC 1315

In Dominion Natural Gas Company, Limited, expenses were incurred to defend an oil franchise; In Ward and Company, Limited (supra), a brewery incurred expenses in anti-prohibition propaganda; In British Insulated and Helsby Cables, Limited v Atherton, [1926] AC 205, the expenditures went toward a pension fund; In Sun Newspapers Limited v The Federal Commissioner of Taxation (1938), 61 CLR 337, monies were paid to prevent the publication of a competitive newspaper; In Morgan v Tate & Lyle Limited, [1955] AC 21, a sugar refinery incurred expenses in a propaganda campaign opposing nationalization; In John Fairfax and Sons Proprietary Limited v Federal Commissioner of Taxation (1958-1959), 101 CLR 30 monies were expended by a company to gain control of another company; In British Columbia Power Corporation Limited v MNR, [1966] CTC 451; 67 DTC 5258, the legal expenses were incurred to recover expropriated shares and to obtain adequate compensation; In Hallstroms Proprietary Limited v Federal Commissioner of Taxation (1946), 72 CLR 634 (H C Austr), legal costs were paid to oppose a petition made by a rival company relative to an extension of certain of its letters patent. ...
T Rev B decision

Santel Investments Limited v. Minister of National Revenue, [1980] CTC 2352, 80 DTC 1305

The Chairman could find out that in- formation”, (SN p 57, lines 13 & 14). ...
T Rev B decision

The Minister of National Revenue v. Vernon W Yorgason, Flora J Yorgason, Taxpayers., [1980] CTC 2560, 80 DTC 1465

(c) Vernon W Yorgason paid the following amounts to Flora J Yorgason in 1974, 1975 and 1976: 1974 $ 8,834.45 1975 10,180.70 1976 8,367.51; (d) Vernon W Yorgason has sought to deduct the aforesaid amounts in the computation of his income for the 1974, 1975 and 1976 taxation years; (e) Flora J Yorgason initially reported the above amount as income for 1974 and then later asked the Minister to delete the same, which he did, and she failed to include any part of the amounts paid to her by Vernon W Yorgason in her income for the 1975 and 1976 taxation years. 4. ...
TCC

Benkarin Holdings Inc. v. R., [1997] 1 CTC 2019 (Informal Procedure)

According to the figures in Schedules I and II, the appellant’s income and profitability were as follows (all figures have been rounded off to the nearest thousand): Profit from Management Fees, Rentals & Gross Income Leases A Office Profit/Loss from Term Dqxwt from Farming 1987 21,000 30,000 31,000 1988 (95,000) 30,000 82,000 1989 (89,000) 27,000 121,000 1990 (98,000) 40,000 126,000 1991 (44,000) 14,000 103,000 During 1989, 1990 and 1991, the years in appeal, the farming activities of the appellant resulted in the following losses: $89,000, $98,000 and $44,000 respectively. ...
TCC

Hanson v. R., [1997] 1 CTC 2456

Counsel for the Appellant argued that there are special circumstances in this case, and in the other cases, which warranted the application acceptance perhaps is a better word, of the due diligence of defence. ...
TCC

Lars Eric Larsson v. Her Majesty the Queen, [1996] 3 CTC 2430, [1998] DTC 2213 (Informal Procedure)

.: These appeals were‘heard in Penticton, British Columbia on June 12, 1996. ...
TCC

Allarcom Pay Television Limited v. Her Majesty the Queen, [1996] 3 CTC 2608, 97 DTC 1558

. /?. [8] for the proposition that the word “goods” in section 125.1 “is used in the common parlance of merchandise or wares, or, to put it in legal jargon, tangible, movable... property”. ...
TCC

Robert E. Angus v. Her Majesty the Queen, [1996] 3 CTC 2618, 96 DTC 1823

(hereinafter “Punters”) and the Appellant was responsible for administering Punters account; (c) The Appellant became involved with the principals of Punters, purchased shares in the corporation, assisted in issuing press releases, introduced potential investors to Punters and attended directors’ meetings; (d) The Appellant acquired and disposed of shares in Punters as detailed in schedule “A” attached hereto and his gains were in the following amounts: 1986: $129,573 1987: $46,731 1988: $ 17,125 (e) The shares acquired by the Appellant in January and March 1986 were acquired on the open market, the purchase price having been paid in cash; (f) The 100,000 shares acquired by the Appellant in June of 1986 were received from Robert Freeland for no cost as they represented a payment for services rendered (Robert Freeland was a venture capitalist and an important source of capital for Punters); (g) At all relevant times the Appellant’s intention was to profit from trading in Punters shares and at no time did he acquire or hold shares in Punters as an investment on account of capital. ...
TCC

Giulio Magliocchetti v. Her Majesty the Queen, [1996] 3 CTC 2660 (Informal Procedure)

.: This appeal is from reassessments of the taxpayer for the 1991 and 1992 taxation years, notices of which were allegedly mailed to the Appellant on May 6, 1994, in which the Minister disallowed the deduction of rental losses, carrying charges and expenses. ...

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