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T Rev B decision

Estate of the Late Rolland Couillard, Couillard Entreprises (Division Construction) Inc, Immeubles Versant Nord Inc, Immeubles Du Coteau Lévis Inc, Place Prévert Inc v. Minister of National Revenue, [1981] CTC 2716

Together with Fernand Couillard, his brother, he founded the firm Fernand & Rolland Couillard (hereinafter referred to as the “F & R company”). ... Sutton Lumber & Trading Company Limited v MNR, [1953] S.C.R. 77; [1953] CTC 237; 53 DTC 1158; 62. ... Osler, Hammond & Nanton Limited v MNR, [1960] CTC 384; 60 DTC 1270; 64. ...
T Rev B decision

MR Lucky v. Minister of National Revenue, [1972] CTC 2412, 72 DTC 1369

Then Bingo Mr Lucky inherited a fortune of almost one million dollars. ...
T Rev B decision

Roman Corporation Limited; v. Minister of National Revenue, [1972] CTC 2321, 72 DTC 1280

Several of the particulars contained in each of the above assessments “A”, “B”, “C” and “D” are set out in the following table: Original Taxation Amount Assessment taxpayer year end in issue A” 1458091-2 First Roman June 30, 1963 $ 31,940.00 ‘B”1458089-2 First Roman June 30, 1962 140,000.00 ‘C” —1458088-2 Trans-Canada March 31, 1964 72,980.57 ‘D” 1458094-2 second Roman June 30, 1965 320,588.81 The following are the particulars of the aforesaid single items in dispute herein as they are spelled out in the above-mentioned assess- ments “A”, “B”, “C” and “D”: Assessment (Primeau Argo Block Company Ltd) $ 31,940.00 “B” Add: Income from trading in securities (Minerales Inndustriales Del Peru) $140,000.00 “C” Add: Profit on disposal of mineral leases $ 72,380.57 “D” Add: Income from trading in securities (Black Hawk Mining Limited) $320,588.81 seemed to me that it was more desirable to get out my decision herein at this time supported only by short reasons general in nature than to hold up the completion of the matter somewhat indefinitely to enable me to summarize the voluminous facts of the matter and to prepare more adequate reasons. ... It should be further observed that, while the profits stated in assessments “B”, “C” and “D” allegedly arose out of the dealings of First Roman, Trans-Canada and Second Roman (ie the three predecessor corporations of the appellant Third Roman) in shares of mining corporations and mineral leases, it is, obviously, more accurate to say on the basis of the evidence and material before me in this matter that the above-mentioned profits arose out of the realization of certain capital assets by the three corporations mentioned above in the ordinary course of carrying on the operation of their respective mining businesses. ... In the result, as indicated earlier herein: the appeal of First Roman with respect to its 1963 taxation year should be dismissed and the relevant assessment “A” 1458091-2 confirmed; the appeal of First Roman with respect to its 1962 taxation year should be allowed and the amount of $140,000 covering income from trading in securities (Minerales Industriales Del Peru) deleted from the relevant assessment “B” 1458089-2; the appeal of Trans-Canada with respect to its 1964 taxation year should be allowed and the amount of $72,380.57 covering profit on disposal of mineral leases deleted from the relevant assessment “C” 1458088-2, and the appeal of Second Roman with respect to its 1965 taxation year should be allowed and the amount of $320,588.81 covering income from trading in securities (Black Hawk Mining Limited) deleted from the relevant assessment “D” 1458094-2. ...
T Rev B decision

Border Fertilizer (1972) LTD v. Minister of National Revenue, [1981] CTC 2780, 81 DTC 778

So, I went back to Ken Aitken Q. By telephone or A. By telephone. And I told him this and he came back Q. Can I just you say, “I told him this”. ... It was in it was beyond November, probably about the middle of November. ...
T Rev B decision

Wayne Bruce Biles v. Minister of National Revenue, [1979] CTC 2411, 79 DTC 358

In computing his income for the 1973, 1974 and 1975 taxation years, the appellant attempted to claim a deduction for alimony payments to his spouse from whom he was living separate and apart pursuant to a written separation agreement, in the following amounts: 1973 taxation year $11,046.16 1974 taxation year $12,197.20 1975 taxation year $11,136.69. ...
T Rev B decision

Andrew Dupej v. Minister of National Revenue, [1982] CTC 2281

With respect to the balance of the total amount for each year, to know in 1976 $1,790.55; in 1977 $1,837.50, these amounts represent interest paid on a personal residence mortgage and, consequently, these expenses are personal and living expenses and cannot be deducted by virtue of paragraph 18(1)(h) of the Act. ...
T Rev B decision

Belton Lumber Company Limited v. Minister of National Revenue, [1972] CTC 2065, 72 DTC 1076

There had been certain added disbursements and expenditures which the appellant had had to make in the attending circumstances, and which can be set forth as follows: Unrecovered balance $73,616 Bank Interest paid by appellant in 1968 $11,337 Legal costs on realization of security $ 3,568 Accounting costs $ 4,000 $92,521 This out-of-pocket balance of $92,521 the appellant sought to deduct from its 1968 income for taxation purposes. ...
T Rev B decision

Lise Gagnon-Chartrand v. Minister of National Revenue, [1983] CTC 2086, 83 DTC 77

Act case law analysis 4.01 Act The provision of the Income Tax Act involved in the case at bar is paragraph 56(1)(b). ...
T Rev B decision

Gordon Glen Marshman v. Minister of National Revenue, [1978] CTC 2475, [1978] DTC 1350

The Respondent, in respect to the assessment of income tax for the Appellant’s 1973 taxation year, acted upon the following findings or assumptions of fact: (a) the facts hereinbefore admitted; (b) the Appellant, in 1973, disposed of a rental property located at 417 Byron Boulevard, London, Ontario; (c) as a result of said disposition, the Appellant realized recapture of capital cost allowance in the amount of $5,620.54; calculated as follows: Proceeds allocated to Class VI depreciable property: $10,426.00 Less: Undepreciated capital cost Class VI depreciable property: $ 4,805.46 Recapture: $ 5,620.54 (d) subsequently the Appellant, in 1973, purchased a 100 acre farm which included certain farm buildings; (e) said farm buildings are also properly included within Class VI depreciable property; (f) the Appellant, in 1973, rented 53 acres of said farm land; (g) the Appellant, in 1973, used the remaining acreage and the farm buildings in the business of farming. ...
T Rev B decision

Agri Holdings Limited v. Minister of National Revenue, [1980] CTC 2908

In June 1971 Peter Sorokolit, President of Villa Theatres & Enterprises, Limited sought permission from the Committee of Adjustment of the City of Toronto to convert a portion of the building on the east side of St. ... On October 21, 1971, Villa Theatres & Enterprises Limited were advised by the committee of adjustment that their application had been refused. ... “Get cost of plans for hotel & apartment. Then decide to whether to.. ...

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