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TCC
Bart Mindszenthy v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2648
Mindszenthy at the time of the trial was a partner in the public relations firm of Mindszenthy & Roberts. ...
TCC
Joseph Raczkovi v. Her Majesty the Queen, [1993] 2 CTC 2746, 93 DTC 1074
Analysis At the outset the Court recognizes that it is possible to be both a trader and an investor at the same time with different properties (see Veltri & Son Ltd. v. ...
TCC
Howard Kamin v. Minister of National Revenue, [1993] 1 CTC 2052, 93 DTC 62
However, if the taxpayer adduces evidence to the effect that such assumptions are no longer reasonable or tenable, the onus of proof may well shift. and at page 156 (D.T.C. 1114):...in my view, at least — it is not sufficient to send to a taxpayer a mass of figures, with little more, and invite or leave him to extricate himself, if he can, from their intended effect. ...
TCC
Oscar J. Forward v. Minister of National Revenue, [1991] 2 CTC 2454, 91 DTC 1255
The verb "entitle", the present tense of "entitled", is defined by The Shorter Oxford English Dictionary On Historical Principles ("Shorter Oxford Dictionary"), as ”... 111. ...
TCC
Dr. Robert Arnold Virtue v. Minister of National Revenue, [1991] 2 CTC 2566, 91 DTC 1340
Further, he says (at page 2402 (D.T.C. 1879)): The reasoning in Steer and Stewart & Morrison has been confirmed in a series of more recent cases. ...
TCC
William Frazer Zwierschke v. Minister of National Revenue, [1991] 2 CTC 2783, 92 DTC 1003
In 1978, the business was transferred to a corporation, Frazer Zwierschke Construction & Trenching Ltd. ...
TCC
Norma E. Henderson, Executrix of the Estate of Harold Henderson v. Minister of National Revenue, [1990] 2 CTC 2086, 90 DTC 1618
On July 18, 1984, the bank under the powers and its debenture, appointed a receiver—Price Waterhouse & Co. ...
TCC
André Coté v. Minister of National Revenue, [1990] 2 CTC 2617, 91 DTC 261
I do not believe that the reason given by Rouleau, J. in the excerpt quoted above was the determining argument in McNeill, for two reasons: (a) Another allowance paid under the same agreement was considered an employment benefit within the meaning of paragraph (1)(a) of the Act because of "the absence of any proof put forward by the plaintiff to show that he actually suffered other losses due to his relocation equal to the [amount] he received [...] ...
TCC
Rudolf Merkle and Rosemarie Merkle v. Minister of National Revenue, [1990] 1 CTC 2090, 89 DTC 730
The appellants' notice of objection filed with the Court makes the following assertion: Section 119(4) allows the averaging period to be the year of averaging and four of the six immediately preceding years —. ...
TCC
Daniel N. Paul v. Minister of National Revenue, [1990] 1 CTC 2413, 90 DTC 1298
She says at page 2211 (D.T.C. 149): ",.. wages are not purchased but paid” and she confirms that since the situs of the income being off the reserve, the income was taxable. ...