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TCC
Bisier v. R., [1997] 3 C.T.C. 2209
Samson merely stated the following diagnosis: [TRANSLATION] “Severe diabetic retinopathy with macular edema and hemorrhaging of vitreous body, Dec. 31/10/90 to 13/11/92 [sic] — Patient's ability to perform a basic activity of daily living markedly restricted.” ...
TCC
Hamelin v. R., [1998] 2 C.T.C. 2126
The problem is that an earlier assessment of tax in an amount which both the Minister and the Appellant agreed was too low resulted in a refund which was seized under the Family Orders and Agreements Enforcement Assistance Act (“ FOAEA ”).The Appellant says that the assessment which gave rise to the refund should not have been made for it was based on an error which the Appellant drew to the attention of the Minister of National Revenue before the assessment was issued. 2 The Appellant retained A to Z Accounting Services of Cornwall, Ontario to prepare his 1995 return of income. ...
TCC
Bootsman v. R., [1998] 2 C.T.C. 2452
It states: (3) Definition of “moving expenses” — In subsection (1), “moving expenses” includes any expense incurred as or on account of (a) travel costs (including a reasonable amount expended for meals and lodging), in the course of moving the taxpayer and members of the taxpayer's household from the old residence to the new residence, (b) the cost to the taxpayer of transporting or storing household effects in the course of moving from the old residence to the new residence, (c) the cost to the taxpayer of meals and lodging near the old residence or the new residence for the taxpayer and members of the taxpayer's household for a period not exceeding 15 days, (d) the cost to the taxpayer of cancelling the lease by virtue of which the taxpayer was the lessee of the old residence, (e) the taxpayer's selling costs in respect of the sale of the old residence, and (f) where the old residence is being or has been sold by the taxpayer or the taxpayer's spouse as a result of the move, the cost to the taxpayer of legal services in respect of the purchase of the new residence and of any taxes (other than the goods and services tax) imposed on the transfer or registration of title to the new residence, but, for greater certainty, does not include costs (other than costs referred to in paragraph (f) incurred by the taxpayer in respect of the acquisition of the new residence. ...
TCC
Audrey Wilson v. Her Majesty the Queen, [1996] 1 CTC 2652 (Informal Procedure)
.: — The appeal of Audrey Wilson was heard on the 27th of September 1995 in the City of Vancouver, and the issue is whether she is allowed to claim a disability deduction in her 1992-93 taxation years. ...
TCC
Michael C. James v. Her Majesty the Queen, [1996] 1 CTC 2789
.: — The Applicant’s solicitor William G.D. McCarthy has brought this Motion for two reasons. ...
TCC
James H. Shaw v. Her Majesty the Queen, [1997] 1 CTC 2736 (Informal Procedure)
.: — This appeal is governed by the informal procedure provided for under section 18 and following sections of the Tax Court of Canada Act. ...
TCC
Martin Feed Mills Ltd. v. MNR, 91 DTC 1069, [1991] 2 CTC 2052 (TCC)
On September 17, 1980 Gillies received a follow-up letter from Coopers & Lybrand, included with which was a summary of "the transactions that are to be concluded before the end of this month”. ... Shantz in turn owned 1,440 of 3,000 issued shares of Trend-Line Glass & Mirror Inc. ... And you have heard the names Laramee Trucking and Trend-Line Glass & Mirror? ...
TCC
Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)
Thompson & Sons Ltd. v. M.N.R. (1966), 41 Tax A.B.C. 1, 66 D.T.C. 291; Admiral Steel Products Ltd. v. ... M.N.R., [1984] C.T.C. 2189, 84 D.T.C. 1140 (T.C.C.); Installation Mécanique G & B Ltée v. ... Thompson & Sons Limited v. M.N.R., supra. If one were to retain the ordinary meaning of the word "processing" as the only guide to its interpretation there would, of course, be very little in our society that could not be categorized as some form of processing. ...
TCC
Chisholm v. The Queen, 99 DTC 150, [1999] 1 CTC 2498 (TCC)
And lastly, Tabs 72 to 75 are minutes of directors’ meetings of Co. 351 held on four successive years showing that dividends were declared as follows: Meeting Date Aggregate Class of Dividend Payable Dividend Shares November 30, 1988 $ 48,000 Common November 30, 1988 November 30. 1989 24.000 Common November 30, 1989 November 30, 1990 12,000 Common November 30, 1990 November 30. 199] 12.000 Common November 30, 199] There is no dispute between the parties concerning any of the documents. ... Cheque to James for his needs $3,286 Family Vacation (James’ 1/5 share of cost) 400 $3,686 Total for James $7,584 Peter- age 12 in 199] Tennis camp $ 1.500 Health club 300 Hockey representative team and hockey camp 1,500 Vacations 1.020 (Peter’s share of costs) Parents’ MasterCard 3,084 (purchases for Peter) Other 2,313 Total for Peter $9,716 Sarah- age 17 in 199] French Immersion in Switzerland Business School in Germany Total expended for Sarah $5,958 James Sarah Peter Total 199] $7,584 $5,958 $9,716 $23,258 1992 11,135 9,665 5,567 26,367 1993 19,302 13,558 6,340 39,200 Paragraph 20(1)(c) of the Income Tax Act is the provision which permits the deduction of interest. ... That purpose — and it is a practical and real one, and in no way remote, fanciful or indirect — is the importation of the losses from the U.S.... ...
TCC
Philip v. R., [1996] 2 CTC 2174, 96 DTC 1893 (Informal Procedure)
.: — The appellant appeals from reassessments made against him on a net-worth basis for the 1988, 1989, 1990 taxation years. ... Also this appears in a number of places “KP & friends”. It is related to such things as framing, roofing, bricklaying and labour. ... Now also in the Mastercard statements that I received, there are a number of — many items in the Mastercard statements that indicate a lot of those things would have been business expenses such as purchases made: Bytown Lumber; Beaver Lumber; Home Hardware; Rentalex and they were counted as personal. ...