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TCC
Alemu v. R., [1999] 3 CTC 2017, 99 DTC 591
The difference is quite striking — over $1,000,000. I shall endeavour to set out briefly my views on how the costs should be awarded in these cases. ...
TCC
Calb v. R., [1999] 3 CTC 2295
This amount was not to be payable, however, until the earlier of two dates — the date upon which 85% of the lots developed on the land were sold, and the date upon which the Appellant had a cash flow sufficient to make the payment. ...
TCC
Prime v. R., [1999] 3 CTC 2342, 99 DTC 565
It occurred in “Prime Transmission & Parts Journal Entries, February 28, 1993” on a sheet dated January 25, 1994. ...
TCC
Gestion Choisy-Tek Inc. v. R., [1999] 3 CTC 2549
Subsection 2900(1) of the Income Tax Regulations (the “Regulations”) defines what is meant by “scientific research and experimental development (“SR&ED”) ” and it does not include development of software in which no technological advancement is involved. ...
TCC
Patry v. R., [1999] 1 CTC 2346
In reassessing, the Minister of National Revenue disallowed the $9,788.00 and all but $2,800.00 of the $10,023.00 ($10,023.00- $2,800.00 = $7,223.00). ...
TCC
General Motors Acceptance Corp. Of Canada Ltd. v. R., [1999] 1 CTC 2623, 99 DTC 294
He complained about the inability to answer questions relating to the sections referred to above which were discussed in a meeting, a Revenue Canada hand written memorandum in respect of which is entitled GMAC-TAX AVOIDANCE 1989 & 1990. ...
TCC
Lever v. R., [1998] 4 CTC 2460
Lever is able to function within the ~ home and that his social interaction is severely limited away from the security of the home. ...
TCC
Wagar v. R., [1998] 4 CTC 2789, 99 DTC 25
He further added: "... that a bookkeeping error of which the sole shareholder was not aware and which he did not sanction and that was not in accordance with the company’s established practices (does not) constitute in reality a method, arrangement or device for conferring a benefit or advantage on the shareholder qua shareholder. ...
TCC
James v. R., [1999] 4 CTC 2036 (Informal Procedure)
In paragraph 12 of the Respondent’s Reply to the Notice of Appeal, the Minister of National Revenue conceded that the Appellant is entitled to a tuition credit in the amount of $272.50 for the 1995 taxation year with respect to the fee he paid for the labour market training project — “Right Choice Driver Training” being a course which he took in 1995. ...
TCC
Scherbakov v. R., [1999] 4 CTC 2073 (Informal Procedure)
Appeal dismissed. 1 ^File No. 88-863 (IT) — page 4 of the Reasons. 2 87 DTC 5443 at 5446 and 5447. ...