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FCTD
Weldon v. The Queen, 80 DTC 6224, [1980] CTC 301 (FCTD)
See S & S Properties Ltd v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294, Hans Reicher v Her Majesty the Queen, [1975] CTC 659; 76 DTC 6001, and MNR v Joichi G Kato et al, [1969] CTC 492; 69 DTC 5308. ...
FCTD
Burri v. The Queen, 85 DTC 5287, [1985] 2 CTC 42 (FCTD)
The Federal Court of Appeal in The Queen v Marsh & McLennan Limited, [1983] CTC 231 at 239; 83 DTC 5180 at 5187, after referring to statements such as that in the Anderson Logging Company case said that: “While this factor is one to be taken into account in a private company in a given case, it cannot of itself be decisive except in the absence of other relevant considerations”. ...
FCTD
Witten v. The Queen, 91 DTC 5041, [1991] 1 CTC 139 (FCTD)
On January 21, 1977, a settlement was reached for a total price of $54,064.50, of which each one-eighth partner in Circle Ten was entitled to $3,379 (" expropriation one”). ...
FCTD
Laframboise v. The Queen, 86 DTC 6396, [1986] 2 CTC 274 (FCTD)
I would further observe that the Minister's authority under subsection 225.2(1) is exercisable when "... it may reasonably be considered that collection of an amount assessed... would be jeopardized by a delay...” ...
FCTD
Global Communications Ltd. v. The Queen, 98 DTC 6649, [1999] 1 CTC 23 (FCTD)
In preparing its 1980 income tax return Global deducted, pursuant to paragraph 20(1)(p) of the Income Tax Act (Canada) (the “ Act”), a bad debt expense in the amount of $1,365,676.00 (the “Bad Debt Claim”). ...
FCTD
Croutch v. The Queen, 86 DTC 6453, [1986] 2 CTC 246 (FCTD)
Optional Value Optional of Inventory Value of From Previous Personal Loss Year Income Inventory Expenses Year Year Consumption Reported 1977 $3,335 $4,575 $15,622 $212 $ 7,500 1978 6,607 14,644 $4,575 567 7,470 1979 4,278 5,000 18,146 413 8,455 1980 5,499 7,000 18,938 5,000 11,439 Where farm losses are incurred by a taxpayer whose chief source of income is nether farming nor a combination of farming and some other source, he may, pursuant to section 31 of the Income Tax Act, deduct only part of the loss. ...
FCTD
Picadilly Hotels Ltd. v. The Queen, 78 DTC 6444, [1978] CTC 658 (FCTD)
The defendant is entitled to costs. 1 "RSC 1952 c 148. 2 *‘The taxpayer stated, in this court, that if the argument pursuant to sub section 11(3d) failed, then the contention based on paragraph 11(1)(f) failed as well. 3 7 The former corporate name was Georgian Towers Hotel Ltd. 4 Ii: The plaintiff had purchased the hotel from Delta Properties Limited who later assigned the agreement for sale to G T Holdings Ltd. 5 The terms of payment after June 1, 1975 are not relevant. 6 "I express no opinion as to what the tax position might have been. if the courts had ultimately granted recission to Oasis, or ultimately awarded damages against the plaintiff. 7 "On the particular facts of the case. the Board member went on to say of the debt in question ‘... though the debt could be looked upon as a doubtful debt in 1964. the decision as to whether the principal shareholder wishes to consider it bad or not rested entirely with him and his business judgment. 8 1 Rev 4th ed (1968). ...
FCTD
Quemet Corp. v. The Queen, 81 DTC 5359, [1981] CTC 472 (FCTD)
Such invoices were issued by Magog in the following amounts: For 1972- $ 2,698.80 For 1973-$14,065.94 For 1974- $57,120.62 For 1975- $62,763.63 For 1976- $10,281.83 Total $146,930.82 Although all scrap metal dealers in the area are now obliged to transact business with their suppliers by cheque, it appears that, until a few years ago and, in any event, during the relevant periods, the market was mostly a cash one and the great majority of suppliers which included peddlers, other scrap dealers and some persons who delivered metals obtained from certain industrial plants, insisted on being paid in cash without furnishing receipts. ...
FCTD
Buonincontri v. The Queen, 85 DTC 5277, [1985] 1 CTC 370 (FCTD)
Funk & Wagnails Standard College Dictionary (1982): Compensation made in any form by a tenant to a landlord or owner for the use of land, buildings, etc, especially when paid in money at regular or specified intervals. ...
FCTD
The Queen v. Riendeau, 90 DTC 6076, [1990] 1 CTC 141 (FCTD), aff'd 91 DTC 5416 (FCA)
.: — Background: This is an application by notice of motion to determine a preliminary question of law. ...