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:—This is an appeal with respect to the taxpayer's 1981, 1982 and 1983 taxation years in which the Minister of National Revenue (” Minister”) disallowed certain interest expenses after computing partnership income from the practice of law. ... Facts The appellant was a partner in the law firm of Morscher & Fehrenbach. ... It is plain and obvious either that generally accepted accounting principles are woefully deficient, or the defendant's argument, depending as it does on the ethics and/or competence of LKH & H, is woefully deficient. ...

.: — This appeal arises out of a determination by the Minister of National Revenue (the “Minister”) ascertaining the amount of the appellant’s non-capital loss for the taxation year ending December 31, 1982, to be $3,032,718. ... Inland Revenue Commissioners, ex parte SG Warburg & Co., [1994] B.T.C. 201, at page 216:... ... West Kootenay Power & Light Co. v. Canada; sub nom. West Kootenay Power and Light Co. v. ...

Cleaver testified Clarkson, Gordon concluded that income earned in the IRA during 1984 was taxable in Canada under section 94 [5] and “ probably subsection 75(2)" [6] of the Act. ... The summary advises the participants that on termination ”... If the total value of your account is $3,500 or more, then, unless you elect an immediate lump sum distribution, you may elect...” to place the funds in various accounts. ... Gill argued the IRA was entered into“ " in substitution for" Abrahamson's right to an amount out of the Case pension plan. ...

After that, there were no more "roof-top episodes " and he was eager to go to school. ... The New Collins Concise Dictionary Of The English Language: "handicap: 1. something that hampers or hinders 2. a contest, esp. a race, in which competitors are given advantages or disadvantages of weight, distance, etc. in an attempt to equalize their chances " The Shorter Oxford English Dictionary devoted 48 lines of type to define the word- as noun and in verb form- as it pertained to sporting events, mainly horseracing and was not particularly helpful. ... " Stedman's Medical Dictionary- 25th Edition (Williams & Wilkins) offers this definition: "handicap- A physical, mental, or emotional condition that interferes with an individual's normal functioning. ...

Therefore, the proper cost number to be assessed is $561,125—$39,000 = $522,125. ... Kelly said Dominic told him, "The old man has lots of money — let's have fun spending it.” ... Either Dominic Calderone thought WH could get away with something and over charge DH, or the whole thing was what Kelly Bennett described — a mismanaged mess. ...

Woolworth building for the sum of $1,120,000 by a notarized contract of sale registered on March 11, 1985 under No. 425593; (o) the appellant realized a profit of $275,261 from the sale of March 6, 1985, calculated as follows: Proceeds of disposition $1,120,000 ACB 844,739 Profit $ 275,261 (p) on February 29, 1984, the appellant and 113064 Canada Ltee each purchased an equal share in a building situated at 2469 rue Langelier in Jonquitre (hereinafter referred to as "the Langelier building") for the sum of $531,000; (q) on December 28, 1984, the appellant and 113064 Canada Ltée sold the Langelier building for the sum of $625,000; (r) the appellant realized a profit of $36,082 from the sale of December 28, 1984, calculated as follows: 1/2 proceeds of disposition $312,000 1/2 ACB 276,418 Profit $ 36,082 (s) during the year in issue, the appellant disposed of a third building, situated on rue Massenet, and realized a profit of $5,420; (t) on October 9, 1980, Mr. ... I would receive my profit from the rents — that is, the sublease that would be granted to me would be on the same terms as those I would require from my tenants. ... M.N.R., [1989] 1 C.T.C. 2272, 89 D.T.C. 165; Veltri & Son Ltd. v. ...

A “Rights & Things” return has been filed under subsection 70(2) of the Income Tax Act, to include the deemed receipt of the RRSPs belonging to the deceased taxpayer. ... See also: Western Smallware & Stationery Co. v. M.N.R., [1972] C.T.C. 7; 72 D.T.C. 6036 at 14 (D.T.C. 6041-2) (F.C.T.D.); Gibbon v. ... We also wish to point out that there is no Death Benefit exemption of $10,000 allowable, as erroneously indicated by Supply & Services Superannuation Divi sion. ...

The value of the farm assets in the years 1980 to 1985 as calculated by the appellant are set out in Exhibit A-10 as follows: The value attributed to the cattle inventory is Harding's estimate of approximate value based on ”... the sales that I purchased the animals at, and what the sales were going at on average at that point in time for those type of animals. ... As to the prices of Chianina cattle in 1980 the test they had:... just come out of the late 70’s when everything was on a wild type swing and prices were escalating and had escalated into the 80's...the Chianina cattle specifically had a price levels [sic] where we saw some little increases from 80 to 81 to 82, somewhere in there, but definitely in 83 right down to 85 they not only fell, they absolutely plummeted whereby we saw purebred cattle that at one time were worth, as an example, $10,000.00 go right to a value of $ 1,500.00 to $2,000.00. ... The amount of $ 10,338.87 included in computing the appellant's income for his 1981 taxation year as a loan by Harding Industries to the appellant in the 1981 taxation year is to be deleted; 3. ...

Act- Case Law — Analysis 4.01 Act The principal provisions of the Income Tax Act applicable in the instant appeal are paragraphs 160(1)(a) and (e) and subsections (2) and 248(1) (definition of the word "property"). ... "There is none — moreover, this is why you have an assessment issued with a number, there is no taxation year in question for the recipient" (trans, pp. 90-91). 4.04.3(2) As to the fact that the notice of notification mentions the taxation year 1985 (para. 3.02.6), counsel added: Further, the notice of notification cannot be used to argue that the Minister chose a year, because this is simply a matter of procedure, and if there are clerical errors in the notice this does not fundamentally vitiate the assessment. ... Only subparagraph 160(1)(3)(ii) refers to this, but to specify the amount of tax owed by the transferor of property ”... in respect of the taxation year in which the property was transferred or of any preceding taxation year". ...

.: — The appeal of Manac Inc. was heard in the city of Montréal, Province of Quebec, on July 18 and 19, 1995. ... “Similar business” = two manufacturing and processing activities, the one manufactures clothing, the other aircraft engines, same business. In Martin & Company (E.P.) Ltd. v. Minister of National Revenue, (1959), 22 Tax A.B.C. 254, the appellant had operated in the sale of clothing before and after a fire in 1955: before the fire, in the retail sale of women’s clothing and, afterward, in the manufacturing and wholesaling of women’s, then men’s clothing. ...