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TCC

Legroulx v. R., [1999] 1 CTC 2833

The $16,900 was calculated as follows: December 1992 $ 650 1993 taxation year 7,800 1994 taxation year 7,800 January 1995 650 Total $16,900 6. ... The total child care expenses of the parties amounts to $3,333 per month ($2,500 + $833). ...
TCC

Mitchell v. R, [1999] 4 CTC 2285, 99 DTC 866

For example, Article 25.00 Fringe Benefits makes reference to a number of matters including the provision of “research monies” and funding for “professional development” and allocates the sum of $60,000 for the support of research in each academic year to be distributed amongst the various faculties. ... T.D.). 12 /?. v. Patterson, supra; Betz v. Minister of National Revenue (1987), 87 D.T.C. 5223 (Fed. ...
TCC

Jeannie Kelner v. Her Majesty the Queen, [1996] 1 CTC 2687 (Informal Procedure)

.: This is an appeal from an assessment for the appellant’s 1991 taxation year whereby the Minister of National Revenue denied the appellant’s claim for child care expenses in the amount of $4,000. ... (c) I state those circumstances in support of my separated status below: 1. we occupied “separate apartments” in the house; 2. we had no sexual relations; 3. we communicated mainly on issues relating to our child who was 2 1/2 years old at the time; 4. my husband performed his own domestic duties, i.e. laundry, cleaning and cooking within the self-contained unit* and he had his own car; * self-contained unit includes separate laundry facilities, separate entrance, separate kitchen (which included table, chairs, refrigerator and stove), bathroom, bedroom and livingroom (including television); 5. social activities together were limited to some family functions which were unavoidable due to the fact that we are first cousins. ...
TCC

Myers’ Humane Information Systems, Patricia Agnes Myers and Carlyle Valentine Myers v. Her Majesty the Queen, [1996] 1 CTC 2801 (Informal Procedure)

.: I shall now render judgment in the appeals of Myers’ Humane Information Systems Inc., Carlyle Valentine Myers and Patricia Agnes Myers. ... Among other things, she claimed half of the apartment rent the apartment where she, her husband and her three sons lived. ...
TCC

Susan Jane Medland v. Her Majesty the Queen, [1997] 1 CTC 2702 (Informal Procedure)

.: This is an appeal from an assessment dated December 22, 1995 issued by the Minister of National Revenue pursuant to section 160 of the Income Tax Act. ... Medland purchased a residence at 14582 18th Avenue, Surrey, British Columbia (the “Property”) for a purchase price of $115,000.00. ...
TCC

Samuel Wuslich v. Minister of National Revenue, 91 DTC 704, [1991] 1 CTC 2473 (TCC)

Prior to, and at all times material to this appeal, he established a " permanent establishment” in Canada, as defined in the Canada- United States tax conventions of 1942 and 1980. ... The document prepared by her, entitled "Allocation of Treatment & Administration Time Between Canada & The United States" was filed as Exhibit A-12. ... By adopting the method already described, he taxed a percentage of the appellant's manufacturing profit,” all of which was earned outside Saskatchewan. ...
TCC

Heather Barnard v. Minister of National Revenue, [1985] 1 CTC 2178, 85 DTC 210

In Ransom v MNR, [1967] CTC 346; 67 DTC 5235, Noël, J said this with reference to paragraph 6(l)(b) of the Act it was paragraph 5(l)(b) at the time relevant to the Ransom decision at page 359 [5243]: A reimbursement of an expense actually incurred in the course of the employment or of a loss actually incurred in the course of the employment is not an “allowance” within the meaning of the word in section 5(l)(b) as an allowance implies an amount paid in respect of some possible expense without any obligation to account. ...
TCC

Robert Moysey v. Her Majesty the Queen, [1992] 2 CTC 2657, 92 DTC 1861

The only difference between the 1991 version of subsection 80(4) and the transitional 1991 version is that the word "deducted" is employed in the latter version rather than the word deductible” after the words equal to the portion of the amount of such interest that was” appearing in the closing portion of these two versions. ...
TCC

Steinberg Inc. v. Minister of National Revenue, [1992] 1 CTC 2191, [1991] DTC 1175, [1992] 1 CTC 2641, [1992] DTC 1478

The evidence in this regard shows that Miracle Mart had never conducted such transactions before signing the licence agreement" with Geneseo. ... Now, how is the licence fee established; how did you come to establish a licence fee of six million dollars (6 000 000 $) for the sale of the business? ... What do you mean by traffic count"? A. That is the number of people walking through the store and making purchases. ...
TCC

Duguay v. R., [1999] 3 CTC 2432

She told him that she knew a Marc Levert, who acquired works of art at auctions and resold them at a low price about 25 percent of their value. ... Lagueux & Frères Inc. (1974), 74 D.T.C. 6569 (Fed. T.D.), in which it was held that to determine the tax consequences of a transaction, the nature of the transaction must be determined under the civil law. ... Duguay [TRANSLATION] “was guilty of gross negligence, or even wilful blindness, in continuing year after year, for five years, to enter into the same kind of simultaneous transaction paying 25 percent in exchange for a tax receipt, no matter what organization and property were involved and in not wanting to see, in the case of Mr. ...

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