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FCA

Carlile v. The Queen, 95 DTC 5483, [1995] 2 CTC 273 (FCA)

That’s a very difficult question because from a planning point of view, we might have been might give you one answer, but a political view would be another answer. ... M.N.R., [1984] C.T.C. 2674, 84 D.T.C. 1548 (T.C.C.), at page 2676 (D.T.C. 1549), best describes my response to the appellant’s claim: I am not persuaded the relevant section [54(c)] of the Income Tax Act permits of the view espoused by this taxpayer that merely because he resided in a housing unit on the property, and used the balance of the property in one way or another to enhance the utility and attractiveness of that domestic living style, he can expand the boundaries of his housing unit to the parameters of the natural domain desired in his appeal. ...
FCA

GSW Appliances Ltd. v. R., 98 DTC 6010, [1998] 1 CTC 335 (FCA)

., at 5241. 4 S.C. 1980-81, c. 48, ss. 10(7). 5 $ Ibid., at 5241, see also Mattabi Mines Ltd. v. ...
FCA

Flexi-Coil Ltd. v. The Queen, 96 DTC 6350, [1996] 3 CTC 57 (FCA)

Nevertheless, he did have the financial statements of the three companies to rely on, and he did- correctly in my view start from the position that the courts should be vigilant in ensuring that a related creditor acted properly in determining that some debts had become uncollectible. ...
FCA

Scott v. The Queen, 94 DTC 6193, [1994] 1 CTC 330 (FCA)

His work encompassed the usual work of a corporate secretary advising directors of meetings, taking minutes, preparing directors' resolutions, etc. ...
FCA

The Queen v. Pan Ocean Oil Ltd., 94 DTC 6412, [1994] 2 CTC 143 (FCA)

Black & Decker Manufacturing Co., [1975] 1 S.C.R. 411, 43 D.L.R. (3d) 393). ...
FCA

Kershaw v. The Queen, 92 DTC 6240, [1992] 1 CTC 301 (FCA)

Nor is there any such evidence respecting his accountants Ernst & Young. ...
FCA

The Queen v. Bryce, 82 DTC 6126, [1982] CTC 133 (FCA)

The following amounts were paid by him: Mortgage $2,148.00 Taxes 655.99 Water & sewer 151.50 Cablevision 59.40 Total $3,014.89 The respondent claimed as a deduction in the computation of his taxable income for the 1975 taxation year the sum of $1,256.20, which is 10/12 of 1/2 of the above total, the decree nisi having been granted in March 1975. ...
FCA

Aztec Industries Inc. v. The Queen, 95 DTC 5235, [1995] 1 CTC 327 (FCA)

This is confirmed by Exhibit R-l which is a detailed letter from Revenue Canada in Toronto to Richter & Partners, the receiver, dated May 6, 1983. ...
FCA

Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)

The term ‘‘uncertified progress claims” as used herein, means progress claims for which architect’s certificates have not yet issued. 2 *lt seems clear from the Co/ford judgment that “holdback” as used therein is used in the wider sense and includes “uncertified progress claims”. 3 TSaid paragraph 85B(1)(b) as it applied to the taxation year 1953 reads as follows: 85B. (1) In computing the income of a taxpayer for a taxation year, (b) every amount receivable in respect of property sold or services rendered in the course of the business in the year shall be included notwithstanding that the amount is not receivable until a subsequent year unless the method adopted by the taxpayer for computing income from the business and accepted for the purpose of this Part does not require him to include any amount receiv able in computing his income for a taxation year unless it has been received in the year; Note: The said paragraph applies also to the taxation year herein under review, ie, 1968. 4 *l use the phrase “at law having regard to the Co/ford decision. ...
FCA

Stursberg v. The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA)

In the event that any partner ("withdrawing partner") wishes to withdraw from the partnership or reduce his partnership interest and concurrently therewith a person ("new partner") wishes to become a member of the partnership to the extent of the reduction amount (as defined below) the withdrawing partner may give to the partnership 30 days' notice in writing ("notice") (which may be waived by all the partners) stipulating the amount by which the withdrawing partner wishes to reduce his partnership interest which amount may be the whole of his partnership Interest (” reduction amount”) and stipulating the identity of the proposed new partner. ...

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