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Giles--------------   Allwest Reporting Ltd. #1200- 1125 Howe Street Vancouver, B.C. ...

Riveros recorded farming income and losses during the years 1987 to 1996 as follows: Taxation Gross Net Year Income Expenses Income (Loss) 1987 $ 8,246.00 $31,407.00 ($23,161.00) 1988 $16,273.00 $44,715.00 ($28,442.00) 1989 $19,412.00 $50,091.00 ($30,679.00) 1990 $23,328.00 $52,228.00 ($28,900.00) 1991 $38,669.00 $65,359.00 ($26,690.00) 1992 $28,228.00 $57,300.00 ($29,072.00) 1993 $39,029.00 $66,857.00 ($27,828.00) 1994 $36,145.00 $68,956.00 ($32,811.00) 1995 $27,803.00 $56,935.00 ($29,132.00) 1996 $31,876.00 $60,618.00 ($27,742.00) [23] The Minister pleaded, and Mr. ...

By notices of reassessment, the Minister added the following four amounts as "additional initiation fee income" to the Appellant's reported income for the four respective taxation years shown below: Taxation Year Amount December 31, 1992 $696,860 December 31, 1993 $335,003 February 18, 1994 $ 71,736 October 31, 1994 $132,693 The amount of $696,860 in the above table was calculated as follows: Initiation fees received in 1992 $357,210 Add initiation fees deferred from prior years 441,154 Subtotal 798,364 Less initiation fees reported as part of net income for 1992 101,504 Additional initiation fee income $696,860 [4] The Appellant claims in paragraph 5 of its Amended Notice of Appeal that, if it does not provide continuous access to and use of its club facilities to a particular member over a ten-year period commencing on the date of initial membership, it is obliged to refund a pro rata portion of the initiation fee which relates to the portion of the 10-year period during which its facilities are not provided to the particular member. ...

I interpret Lord Wright’s test not as the fourfold one it is often described as being but rather as a four-in-one test with emphasis always retained on what Lord Wright, supra, calls “ the combined force of the whole scheme of operations,” even while the usefulness of the four subordinate criteria is acknowledged. ...

I will summarize these Exhibits as follows: Year Gross Sales Net Sales Expenses Loss/Profit* 1991 $2,788 ($288) $5,114 ($5,402) 1992 6,406 (3,558) 8,347 (11,905) 1993 1,401 (98) 17,476 (17,574) 1994 1,019 1,020 5,404 (4,384) 1995 360 360 9,425 (9,065) * Before automobile expenses In 1991 and 1992, the losses were allocated between the Appellant and his wife. ...

In filing her income tax return for the 1994 taxation year, the Appellant reported total income before deductions in the amount of $183,840, calculated as follows: Employment Income $ 65,000 Interest and other investment income 28,840 Business Income 90,000 $183,840 The business income of $90,000 represented a management fee paid to the Appellant by Holdings. ...

But without the tax bills being produced, and saying this is the assessment, it's so much for land and so much for building, all I can sit here and say is the figures look very peculiar to me. [34] Judge Rowe's decision in Howard & Davis v. ...

An ABIL is defined in paragraph 38(c) as ¾ of a taxpayer's business investment loss. [5] Business investment loss is defined in paragraph 39(1)(c) as follows: (c) a taxpayer's business investment loss for a taxation year from the disposition of any property is the amount, if any, by which the taxpayer's capital loss for the year from a disposition after 1977 (i) to which subsection 50(1) applies, or (ii) to a person with whom the taxpayer was dealing at arm's length of any property that is (iii) a share of the capital stock of a small business corporation, or (iv) a debt owing to the taxpayer by a Canadian-controlled private corporation (other than, where the taxpayer is a corporation, a debt owing to it by a corporation with which it does not deal at arm's length) that is (A) a small business corporation, (B) a bankrupt (within the meaning assigned by subsection 128(3)) that was a small business corporation at the time it last became a bankrupt, or (C) a corporation referred to in section 6 of the Winding-up Act that was insolvent (within the meaning of that Act) and was a small business corporation at the time a winding-up order under that Act was made in respect of the corporation, exceeds the total of... ...

Accordingly, I have instructions to proceed with a Petition for Divorce and Motion, if we do not have confirmation that the terms in paragraphs 1 – 10 are acceptable, within five days. ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] This is an appeal for the 1995 taxation year. [2] The issue is whether the appellant knowingly, or under circumstances amounting to gross negligence, failed in his 1995 income tax return to report a capital gain on the disposition of qualified shares of a small business corporation, in respect of which gain subsection 110.6(2.1) of the Income Tax Act ("the Act ") provides for a $375,000 exemption in computing taxable income. ...