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EC decision
Western Minerals Limited v. Minister of National Revenue, [1961] CTC 477, 61 DTC 1270, [1961] CTC 476
I rejected the contention thus put forward and held, as set out in the headnote of the case, as follows: “ Held: That it is not for the Court or anyone else to prescribe what the intensity of the examination of a taxpayer’s return in any given case should be. ...
EC decision
Minister of National Revenue v. Harry Edgar Morden, [1961] CTC 484, 61 DTC 1266
In the re-assessments, all dated September 13, 1954, the Minister added to the declared income of the respondent the following amounts: 1949 $ 1,500 1951 (reduced by the Minister’s Notification from $10,250) 10,000 1952 860 1953 1,500 The re-assessments indicated that the amounts so added were in relation to net gains from gambling activities. ...
EC decision
Irrigation Industries Ltd. v. Minister of National Revenue, [1960] CTC 329, 60 DTC 1232
When the former tenants vacated, substantial repairs were made to the building and it appears to have been rented from about January 1, 1953, at $1,500 per month, to Locke Gray & Co., a firm with which Mr. ...
EC decision
Louis Norman Horowitz v. Minister of National Revenue, [1962] CTC 17, 62 DTC 1038
Section 59 provided for an appeal to the Income Tax Appeal Board to have the assessment to which objection had been taken vacated or varied and prescribed the time within which such appeal might be instituted, as follows: ‘ ‘59. (1) Where a taxpayer has served notice of objection to an assessment under section 58, he may appeal to the Income Tax Appeal Board constituted by Division I to have the assessment vacated or varied after either (a) the Minister has confirmed the assessment or re-assessed, or (b) 180 days have elapsed after service of the notice of objection and the Minister has not notified the taxpayer that he has vacated or confirmed the assessment or re-assessed; but no appeal under this section may be instituted after the expiration of 90 days from the day notice has been mailed to the taxpayer under section 58 that the Minister has confirmed the assessment or re-assessed. (2) Service of a notice of appeal under this section shall be served and all other matters in connection with an appeal under this section shall be regulated by Division I.” ...
EC decision
Edouard Galipeau v. Minister of National Revenue, [1962] CTC 289, 62 DTC 1178
Davie & Sons v. M.N.R., [1954] Ex. C.R. 280; [1954] C.T.C. 124, servent à me confirmer dans l’opinion que j’adopte. ...
EC decision
Donald Quon and Lee K. Yuen v. Minister of National Revenue, [1962] CTC 343, 62 DTC 1204
The appellant Quon also subsequently participated with others in the purchase of what was referred to as the Berraby (?) ...
EC decision
Roger L. Vincent v. Minister of National Revenue, [1965] CTC 65, 65 DTC 5056
As the Minister has been successful on all matters that were in controversy between the parties at the hearing of the appeal the Minister shall be entitled to his costs, except any costs related exclusively to the items with respect to which the assessments are being referred back and the appellant shall be entitled to a set-off in respect of any costs incurred by him relating to such items. 1 * Section 139(1) (az) was repealed by Section 33(3), chapter 43, S.C. 1960 and by Section 33(5) of the same statute Section 139 (la) (a) was added. ...
EC decision
The Queen v. Dante Albert Saracini and Albert Saracini, [1958] CTC 355, 59 DTC 1005
I think, in this respect, the practice of the Department is right. ’ After careful consideration of that case, I am unable to distinguish it from the one now before me. ...
EC decision
Her Majesty the Queen v. Rexair of Canada Limited, [1956] CTC 108, 56 DTC 1056
He goes on to say: “ It is clear from the contract and the evidence that English and Metcalf were manufacturing the toys for the defendant only. ...
EC decision
Minister of National Revenue v. John Pawluk (Sr.), [1955] CTC 369, 55 DTC 1234
There are observations by noble and learned Lords in Bwllfa & Merthyr Dare Steam Collieries (1891) Ltd. v. ...