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TCC

Ann D. Sparkes v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 3162

Accordingly, A.V.C.s are excluded from the ambit of the rules in paragraph 147.2(4)(b) and (c) concerning service before 1990 i.e. they are not deductible thereunder. ... The 18 per cent contribution limit applies (directly or indirectly) to all types of registered retirement income vehicles (that is, R.P.P.s, deferred profit sharing plans [D.P.S.P.s], and R.R.S.P.s). ...
TCC

James Catton and David v. Listoe v. Minister of National Revenue (Informal Procedure), [1993] 1 CTC 2108, 93 DTC 117

S.C. 1970-71-72, c. 63) (the"Act"), as amended and sections 7302 and 7303 of the Income Tax Regulations (” Regulations”) applicable to the 1988 and 1989 taxation years. ... At the hearing, neither the appellant nor Crown Counsel raised the fact that section 110.7 had been amended applicable to the 1988 and subsequent taxation years in such fashion that the term prescribed area” no longer appeared therein. ...
TCC

The Estate of the Late William Tatarchuk v. Minister of National Revenue, [1993] 1 CTC 2440

& Fin. 85, 8 E.R. 1034 (H.L.)]. (b) William J. compared the forged signature on the cheque with the signature on Exhibit A-2 and testified that in his opinion neither was that of his father. ... The assessment of William Tatarchuk for 1986 included the following amounts in his income: The inclusion of the sum of $66,628.67 was based on the assumption that in the 1986 taxation year William Tatarchuk, deceased, deregistered RRSP funds in the amount of $66,628.67 and that he received in 1986 RRSP funds from the National Trust Company as follows: Deemed receipt on deregistration $ 66,628.67 Deemed receipt on death 45,799.91 TOTAL $112,428.58 Contract No. 10206 $12,739.34 Contract No. 10207 12,739.33 ER 10508 41,150 TOTAL $66,628.67 It is only the sum of $41,150 that is in issue in this case. ...
TCC

Donald Phillips v. Minister of National Revenue, [1992] 2 CTC 2524, 92 DTC 1999

As a result of this, in the appellant's words, at that juncture, Everything had to go on hold”. ... Teaching Gross Farm Farm Income Income Expenses Farm Losses Farm Profit 1982 $43,584 $10,100 $19,735 $ 9,635 1983 43,856 12,484 24,531 12,048 1984 44,596 10,200 22,000 11,800 1985 49,676 10,531 21,498 10,966 1986 53,332 10,239 19,155 8,916 1987 53,018 11,423 17,360 5,931 1988 54,904 12,691 14,779 2,087 1989 57,363 290 Respondent's counsel stated that all losses would have been greater had the appellant claimed capital cost allowance as required by the decision in Mold- owan v. ...
TCC

Edith D’argys v. Minister of National Revenue, [1992] 2 CTC 2778

Hereinafter called "THE TRANSFEREE" WHICH PARTIES have agreed as follows: The transferor does hereby transfer and cede all of his rights, titles and interest in the immoveable property hereinafter described, unto the transferee herein, hereto present and accepting, namely: DESCRIPTION An immoveable property situated on Hortie Street in the City of Pierrefonds, known and described as lot number TWENTY-EIGHT of the official subdivision of the original lot number TWENTY-ONE (21-28) according to the official plan and book of reference of Ste-Geneviève Parish. ...
TCC

Victoria Privitera v. Minister of National Revenue, [1992] 1 CTC 2227, 92 DTC 1122

" She described her intentions with respect to the assets as \ expected to get my share” and "that the properties would be divided equally”. ... With respect to the fact that Victoria would be required to pay income tax on the $2,000 per month counsel stated Well, in this instance Mrs. ...
TCC

John M. Fedyna and Fedyna Construction Limited v. Minister of National Revenue, [1991] 2 CTC 2288, 91 DTC 1014

.: The appeals of John M. Fedyna v. M.N.R. (88-84IT) and Fedyna Construction Ltd. v. ... The basic dispute in these appeals concerns the interpretation of the last clause in Exhibit A-6: ”... and if title is not conveyed to John Fedyna, the $4,200 indicated above is deemed to be rent for the house and contents.” ...
TCC

Henry R. Loewen v. Minister of National Revenue, [1990] 1 CTC 2133, 90 DTC 1009

At the Closing, the Issuer will execute and deliver to the Purchaser the Debenture, and the Purchaser will pay the purchase price to the Issuer as follows: (a) as to $24,000, by delivery of a cheque for $24,000 drawn on the trust account of Anderson, Baillie & Company, and (b) as to the balance, by delivery of a promissory note in the amount of $176,000 and substantially in the form attached hereto as Schedule B. 4. ... Finsbury Securities Ltd., [1966] 3 All E.R. 105; FA & AB Ltd v. Lupton, [1971] 3 All E.R. 948. ...
TCC

Dorothy Kazakoff and Fred Kazakoff v. Minister of National Revenue, [1990] 1 CTC 2203, 90 DTC 1073

By notices dated August 10, 1984 the respondent reassessed each appellant and treated each appellant's full gain of $ 19,331.50 from the sale of the property as income earned in that year from an adventure or concern in the nature of trade. ... He responded ”... that's what they put down" but asserted that he did not recall telling the bank manager that he was going to purchase the Kaleden property for resale. ...
TCC

Sharon Stewart and Ron Dilabio (Joined Party) v. Minister of National Revenue, [1990] 1 CTC 2231, 90 DTC 1110

Sweet & Maxwell, 1985, we read at page 95: The extent of the implied authority of a solicitor to compromise is however not clear. ... (On this matter, see McClelland & Stewart Ltd. v. Mutual Life, [1981] 2 S.C.R. 6 at 15.) ...

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