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EC decision
Harvey Clarke Smith v. Minister of National Revenue, [1960] CTC 391, 60 DTC 1282
’?’’ The test is not always easy to apply, for there is no single criterion by which the question may be resolved, and cases frequently arise in which there are circumstances or facts pointing to both conclusions. ...
EC decision
Hersch Fogel v. Minister of National Revenue, [1959] CTC 227, 59 DTC 1182
It is quite true that they preferred not to sell them if a sale could be avoided, but the statement in para. 11 of the case is quite plain, that ‘ the possibility of the sale of the foreign patents or rights has always been contemplated by the appellant company in respect of such interest as it possessed in the foreign patents.’ ...
EC decision
Minister of National Revenue v. Joseph A. Simard, [1962] CTC 310, 62 DTC 1192
Selon ces articles lorsqu’un contribuable a signifié un avis d’opposition à une cotisation, prévu 2‘1 l’article 58, il peut interjeter un appel contre la cotisation 2‘1 la Commission d’appel de l’impôt ou 2‘1 cette Cour en suivant les conditions prescrites par l’article 59, c’est-à-dire ‘ (a) après que le Ministre a ratifié la cotisation ou procédé 2‘1 une nouvelle cotisation, ou (b) après l’expiration des cent quatre-vingt jours qui suivent la signification de l’avis d’opposition sans que le Ministre ait notifié au contribuable le fait qu’il a annulé ou ratifié la cotisation ou procédé 2‘1 une nouvelle cotisation.” ...
EC decision
Edwin L. Schujahn v. Minister of National Revenue, [1962] CTC 364, 62 DTC 1225
The appellant upon hearing of his transfer back to Minneapolis contacted, in July 1957, a firm of real estate agents in Toronto, Key & Penn, and told them to try to sell his house. ...
EC decision
Harry Sheftel, Benjamin Sheftel an Leopold Sheftel v. Minister of National Revenue, [1965] CTC 201, 65 DTC 5133
On April 25, 1958 the city replied enclosing a ‘c of the decision of the Technical Planning Board stating that the request to operate a feed lot on the premises was considered and refused because the property had been classified on the interim zoning guide as ‘‘ Agricultural future residential’’ which did not permit the development of feed lots and that feed lots were only permitted in heavy industrial areas under special The appeal procedure from such refusal was explained but no appeal was launched because, as Harry Sheftel testified, hé considered an appeal to be futile having been so informed by a civic official who also indicated to Harry Sheftel that he would vigorously oppose such an appeal. conditions. ...
EC decision
William Slater, Sam Ross, David Ross, Betty Slater, Ida Ross, Helen Ross an Gerald Ross v. Minister of National Revenue, [1966] CTC 53, 66 DTC 5047
Ross & Sons Limited, which came into existence when the partnership was dissolved and which in the years 1956, 1957 and 1959 was active in the building of houses for resale. ...
QCQC decision
The Minister of National Revenue for the Dominion of Canada, [1952] CTC 175
Cammel Laird & Co. (1942), L.J.R. 406, it is pointed out that the refusal to disclose is sometimes based on the fact that the information is of a type which, on the broad rule of public policy and convenience, should be kept secret and that it is at other times based on the fact that it belongs to a class of information which should not be revealed. ...
FCTD
Grandmont v. Canada (Attorney General), 2023 FC 1765
DATED: December 28, 2023 APPEARANCES: Janie Grandmont FOR THE APPLICANT ON HER OWN BEHALF Samantha Jackmino FOR THE RESPONDENT SOLICITORS OF RECORD: Attorney General of Canada Montréal, Quebec FOR THE RESPONDENT ...
EC decision
Appeal Dismissed. Harvey Clarke Smith v. Minister of National Revenue, [1960] CTC 390
’?’’ The test is not always easy to apply, for there is no single criterion by which the question may be resolved, and cases frequently arise in which there are circumstances or facts pointing to both conclusions. ...
FCTD
Her Majesty the Queen v. E J Piggott Enterprises Limited, [1973] CTC 65
The plaintiff also alleges that by reason of further sales and deliveries of such equipment and supplies in the period from August 1, 1966 to the end of 1967 the company became further liable for sales tax at 12%, making a tax liability of $715.55, which the company neglected, failed or refused to pay (paragraph 5 of the Information); and that by reason of non-payment of that liability the company became liable to penalties that amounted to $159.79 to April 30, 1970 (paragraph 6), In the Information the plaintiff alleges that the amounts remaining unpaid and owing to Her Majesty by the defendant were: Penalties to August 12, 1968, $ 602.10 Tax unpaid 715,55 Penalties on said tax to April 30, 1970 159.79 Total $1,477,44 and the plaintiff claims: (a) payment of that sum of $1,477. 44: (b) payment of additional penalties and interest accruing under the Act, until judgment; (c) costs. ...