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TCC

Larsen v. The Queen, docket 97-2648-IT-G

Investments Inc. a profit à prendre when they granted it "... a right to remove timber from the properties" (Exhibit AR-1, Tab 4, page 1). ...
TCC

Bates v. The Queen, docket 97-120-IT-G

Was he ambivalent about making “provision in the order for the impact of income tax” because of his prior statement in the endorsement: “... clearly the Husband has the ability as indeed does the Wife to provide support”? ...
TCC

Ng v. The Queen, docket 97-2104-IT-I (Informal Procedure)

By putting them to Revenue Canada, he could be taken to have satisfied the reasonable test because, in the words of the Appellant’s agent: “the Appellant was not possessed of knowledge of the intricacies of the Income Tax Act ”. ...
TCC

Krol v. M.N.R., docket 97-2046-UI

Although the Minister admitted that the Appellant is very experienced and skilled in the areas of gardening (paragraph # 1, under Statement of facts in the Reply) in his assumptions, he stated it was not known if the Appellant is a fully qualified landscape worker. ...
TCC

Fletcher Challenge Investments Inc. v. The Queen, docket 96-3693-IT-G

In Everest & Jennings Canadian Ltd. v. Invacare Corporation, [1984] 1 F.C. 856, the Federal Court of Appeal cited with approval the decision of the British Columbia Court in Boxer and Boxer Holdings Ltd. v. ...
TCC

Thunder Bay Symphony Orchestra Assn. Inc. v. M.N.R., docket 97-1348-UI

". There is no doubt in my mind that the Master Agreement not only looks like a collective agreement but is in fact a collective agreement. [18] Having decided as an issue of fact that the Master Agreement is a collective agreement because all significant terms of engagement of each core musician are governed by the Master Agreement, I could conclude that each core musician is an employee of the Appellant and not an independent contractor. ...
TCC

Rehberg v. M.N.R., docket 97-1479-UI

Box 28091 RPO, Tacoma, Dartmouth Nova Scotia, Postal Code B2W 6E2 for the following purposes and objects, namely: Painting & Construction trades, 3 Fernhill Rd. ...
TCC

Moore v. M.N.R., 2007 TCC 643

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

Riveros v. The Queen, docket 98-2945-IT-I (Informal Procedure)

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. ...
TCC

Argus Holdings Ltd. v. The Queen, docket 97-2301-IT-G

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. ...

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