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MNR, 91 DTC 1265, [1991] 2 CTC 2442 (TCC)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) In dealing with a submission that a Revenue Canada official had given the taxpayer some assurance that the taxpayer would not be assessed under s. 227.1, Mogan J. stated (p. 1270): "... ...

BCN Ltée, 79 DTC 5068, [1979] CTC 71, [1979] 1 S.C.R. 865-- summary under Disposition of Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Disposition of Property disposition by virtue of merger of leasehold interest and freehold The verb "to dispose" (which should receive the same meaning as the expressions "disposition", "proceeds of disposition" and " disposed of") should be given the broadest possible meaning, and encompasses the idea of destruction or extinguishment. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) In finding that even if (contrary to her actual finding) that amounts received for non-compete covenants by the taxpayer were taxable, penalties would not have been applicable, Lamarre TCJ. stated (at p. 72): "... considering all the different positions taken by the Minister to try to justify his own assessments, I do not see how we can attribute to the appellants a degree of negligence... when especially they have obtained professional advice that the NCA payments were not taxable. ...

The Queen, 96 DTC 6040 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

The Queen, 96 DTC 6040 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement gift rceeived in course of business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Pension Income Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7)- Pension Income periodic discretionary withdrawals ≠ periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Annuity Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Annuity periodic discretionary withdrawals ≠ periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...

Mogan T.C.J. found that deduction of ¾ of these losses as allowable business investment losses was not precluded by s. 40(2)(g)(ii) in light of the decision in Business Art Inc. v. ...

The Queen, 2012 TCC 105-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...

The Queen, 2012 TCC 105-- summary under Paragraph 4(1)(a) Summary Under Tax Topics- Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to incur "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...