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TCC

William G. Docherty v. Minister of National Revenue, 91 DTC 537, [1991] 1 CTC 2409 (TCC)

Tudhope, Anderson & Co. (1911), 19 W.L.R. 141; 21 Man. R. 380 (Man. ...
TCC

Kalousdian v. The Queen, 94 DTC 1722, [1994] 2 CTC 2127 (TCC)

. $100,000 at Toronto together with interest @ 11.5 per cent per annum. ...
TCC

Montplaisir Ltée v. MNR, 92 DTC 2317, [1992] 2 CTC 2700 (TCC), aff'd 96 DTC 6557 (FCTD). aff'd 2001 DTC 5366 (FCA)

Chairman Cardin made the following observations at page 2220 (D.T.C. 160): The evidence is that, in the loss application years, only some of the assets in the appellant's Maritime operations were sold; the appellant continued to seek- out and to bid on tenders for its marine construction operations in the Maritimes; a marine construction contract was awarded and carried out by the appellant in Newfoundland in the loss application years; marine construction contracts on which bids were made could have been executed in the Maritimes, either with the appellant's marine equipment already located in Halifax or with equipment transported from the company's Great Lakes & St. ...
TCC

Barnabe Estate v. Minister of National Revenue, 98 DTC 1824, [1998] 3 CTC 2201 (TCC)

. /?., [1990] 2 C.T.C. 464, 90 D.T.C. 6617 (Fed. C.A.), Hugessen, the Federal Court of Appeal stated, An election by a taxpayer under section 85 must be made in such a way that it is possible to determine in respect of which property it is made. ...
TCC

Stanley Drug Products Ltd. v. MNR, 90 DTC 1664, [1990] 2 CTC 2646 (TCC)

This reasoning was followed by the House of Lords in the case of FA & AB Ltd. v. ...
TCC

ELB Productions Ltd. v. MNR, 91 DTC 1466, [1991] 2 CTC 2661 (TCC)

The Dun & Bradstreet report on WGL indicated that it was incorporated in September 1984, and commenced business in October 1984. ...
TCC

Gordon v. The Queen, 96 DTC 1554, [1996] 3 CTC 2229 (TCC)

.: This is an appeal from a Notice of Reassessment wherein the Minister of National Revenue (the “Minister”) reassessed the Appellant’s tax payable for the 1990 taxation year. ...
TCC

Beutler v. MNR, 88 DTC 1286, [1988] 1 CTC 2414 (TCC)

The facts in this case, it was said, are different from the reported cases of Lloyd Youngman & Company Inc., Trustee of the Estate of Harold Fraser in Bankruptcy v. ...
TCC

Ingram v. MNR, 91 DTC 939, [1991] 2 CTC 2259 (TCC)

However, the Robert & Collins French-English Dictionary, 2d edition, 1988 interprets "interdit" as "forbidden" or "prohibited" and does not interpret that word to mean "capacity". ...
TCC

163410 Canada Inc. v. The Queen, docket 97-1752-GST-G

Second, and this point is even more important, the firm agreed to establish its fees [TRANSLATION] "in the same way as if 163410 were a regular client... and as if they had to be paid... by MIDLAND ". [9] The appellant's funds were thus used by Midland to pay Heenan Blaikie's fees, as is evidenced by the document entitled [TRANSLATION] "Statement of Account" in Exhibit A-10. [10] I consider that the agreement of May 12, 1992 between Midland and the appellant, to which Heenan Blaikie was also implicitly a party by reason of its undertakings (as clearly set out in paragraph 4 of the agreement), concerns the supply of legal services and alters the initial agreement between Midland and Heenan Blaikie in this regard. [11] In my opinion paragraph 4 of this agreement of May 12, 1992 is thus an agreement for a supply of legal services under which the appellant, not Midland, is designated as the person who is liable to pay the consideration for the supply. ...

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