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. — Impenco Ltee v. Minister of National Revenue, [1988] 1 CTC 2339, 88 DTC 1242 Couture, C.J.T.C. ... It was established in cross-examination that between 1981 and 1986 the appellant had the following gross and net income and made these contributions to charitable organizations: Gross Income Net Income For Charitable Donations Tax Purposes 1981 $4,026,113 $ 82,507 1982 5,186,382 $ 546,597* [1] 104,226 1983 6,436,017 1,154,097 * 186,115 1984 4,577,312 456,065 178,097 1985 5,472,160 368,288* 186,307 1986 5,279,177 388,395 188,985 Mr. ... In Olympia Floor & Wall Tile v. M.N.R., [1970] C.T.C. 99; 70 D.T.C. 6085 Jackett, P. ...

Dew Engineering & Development Ltd. v. Her Majesty the Queen, [1996] 3 CTC 2904 O’Connor J.T.C.C.: — This appeal was heard at Ottawa, Ontario, on August 6, 1996 pursuant to the General Procedure of this Court. ... IT-79R3 provides: Meaning of “Building ” and “Structure ” 1. “Building” is a term of wide range covering any structure with walls and a roof affording protection and shelter. ... There is an argument to be made that section 37 is required to allow SR & ED costs to be deducted. ...

Women in Film & Television Toronto Inc. v. M.N.R., docket 97-1402-UI Date: 19981209 Dockets: 97-1402-UI; 97-150-CPP BETWEEN: WOMEN IN FILM & TELEVISION TORONTO INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and MARGOT La ROCQUE, Intervenor. ... At that time WIFT-T employed one or two employees to carry out office / administrative functions for the organization. ... In a letter dated May 9, 1997 Revenue Canada, Appeals issued a letter (...) confirming their assessment. ...

& J. Engineering Corporation v. Minister of National Revenue, [1992] 2 CTC 2235 Bonner, T.C.C.J. ... It took the position that the amounts received by it in 1985 and 1986 were ” pre-payments" or " deposits” on a contract which it had yet to complete. ... It was the position of counsel for the appellant that the deposit received by the appellant in 1985 [1] and the amounts received by it in 1986 under the CN contracts were ” prepayments". ...

& Candor Investments Ltd. v. Minister of National Revenue, [1989] 2 CTC 2076, 89 DTC 355 Kempo, T.C.J. ... May 1978 “Keg Building” 605-11th Avenue S.W., Calgary — Renovate and rent. b. ... Fall 1978 to mid 1979 "Petro Canada Land" 101-6th Avenue S.W., Calgary — Land accumulation/assembly — Redevelopment project. d. ...

Justice MacGuigan in West Kootenay Power & Light Co. v. R., (sub nom. ... Nomad Sand & Gravel Ltd. v. Canada), [1991] 1 C.T.C. 60, (sub nom. ... In the case of Newfoundland Light & Power Co. v. R., (sub nom. Newfoundland Light & Power Co. v. ...

In the instant matter, the applicant, Milan Hrovat, did not appear — he apparently could not, due to a medical problem. However, both of the partners of the accounting firm Folkard & Co, a Mr Rupert N Folkard, CA, and Mr Sam Ramessar, CA, did give testimony. ... The Minister’s assertion must be directed, therefore, toward the second issue — the involvement of the agents, Folkard & Co. ...

Paragraph 37(1)(a) of the Act refers to an expenditure of a current nature made on SR & ED. Paragraph 37(8)(«) of the Act provides that expenditures on or in respect of SR & ED are expenditures directly attributable to the prosecution of SR & ED. ... However, how can a salary paid on the basis of a business’ liquid assets be connected with SR & ED? ...

Installation Mécanique G & B Ltée v. Minister of National Revenue, [1987] 1 CTC 2326, 87 DTC 226 Tremblay, T.C.J. ... The work to be performed was as follows: repair "the hopper — building 310 in accordance with the sketch attached hereto and Mr. ... Act — Case Law — Analysis 5.01 Act The provisions chiefly involved in this case are paragraphs 125.1 (3)(a) and (b) of the Income Tax Act and section 5200 of the Income Tax Regulations. ...

K & D Logging Ltd. v. The King, 2023 TCC 23 Docket: 2017-4536(IT)G BETWEEN: K&D LOGGING LTD., Appellant, and HIS MAJESTY THE KING, Respondent.   ... APPENDIX   Relevant Statutory Provisions:   CITATION: 2023 TCC 23 COURT FILE NO.: 2017-4536(IT)G STYLE OF CAUSE: K & D LOGGING LTD. ... Quo Vadis   Firm: Koffman Kalef For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   [1] C. ...