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TCC
Anthony P. Gay v. Her Majesty the Queen (Informal Procedure), [1993] 1 CTC 2150, 93 DTC 96 (Informal Procedure)
Her Majesty the Queen (Informal Procedure), [1993] 1 CTC 2150, 93 DTC 96 (Informal Procedure) Watson, T.C.C.D.J. ...
TCC
Gestion Guy Menard Inc. And Guy Menard Inc. v. Minister of National Revenue, [1993] 1 CTC 2375
Minister of National Revenue, [1993] 1 CTC 2375 Lamarre Proulx, T.C.C.J. ...
TCC
Reginald D. Richardson v. Minister of National Revenue, [1993] 1 CTC 2458, 93 DTC 258
Minister of National Revenue, [1993] 1 CTC 2458, 93 DTC 258 Brulé, T.C.C.J. ...
TCC
Jean Bouchard v. Minister of National Revenue, [1993] 1 CTC 2622, 93 DTC 1163
Minister of National Revenue, [1993] 1 CTC 2622, 93 DTC 1163 Lamarre Proulx, T.C.C.J. ...
TCC
Jacques Bergeron, George Demers and Michel Bouchard v. Minister of National Revenue, [1993] 1 CTC 2625, 93 DTC 700
Minister of National Revenue, [1993] 1 CTC 2625, 93 DTC 700 Tremblay, T.C.C.J. ...
TCC
Ben Weinstein v. Her Majesty the Queen, [1993] 1 CTC 2714, 93 DTC 318
Her Majesty the Queen, [1993] 1 CTC 2714, 93 DTC 318 Christie, A.C.J.T.C.C. ...
FCTD
Rivermede Developments Ltd. v. The Queen, 93 DTC 5365, [1993] 2 CTC 220 (FCTD)
Crang admits that plaintiff also did nothing with the Dufferin Street property (the property in issue) before selling it (page 25 of March 31, 1993 transcript). ... I really don't know" (page 90, March 31, 1993 transcript). This is his explanation. ... [Pages 71 and 72, transcript April 1, 1993.] The commercial complex (shopping centre) was a very small portion of the total overall industrial leasehold program". ...
TCC
Viceroy Rubber and Plastics Ltd. v. MNR, 93 DTC 347, [1993] 1 CTC 2343 (TCC)
MNR, 93 DTC 347, [1993] 1 CTC 2343 (TCC) Brulé, T.C.C.J.:—These are appeals for the taxpayer's 1984 and 1985 taxation years in which the Minister of National Revenue ("Minister") assessed the appellant for income tax within the meaning of paragraph 212(1)(d) of the Income Tax Act ("Act") plus interest and penalties. ... Sarchuk, J., in a recent decision in January 1993, that of Kamsel Leasing Inc. v. M.N.R., said (see [1993] 2 C.T.C. 2279): In the present appeal there is sufficient evidence upon which I can conclude that a lessee had the right at the expiration of the lease to acquire the property at a price which at the inception of the lease could be said to be substantially less than the probable fair market value of the property at the time of permitted acquisition. ...
TCC
Saratoga Building Corp. v. MNR, 93 DTC 564, [1993] 2 CTC 2074 (TCC)
MNR, 93 DTC 564, [1993] 2 CTC 2074 (TCC) Brulé, T.C.C.J.:—The appellants, Saratoga Construction Ltd. ... M.N.R., [1993] 1 C.T.C. 2153, 93 D.T.C. 127 (T.C.C.); Sandell Developments Ltd. v. ... M.N.R., [1993] 1 C.T.C. 2153, 93 D.T.C. 127 (T.C.C.). Appellant’s position Counsel for the appellants took the position, based on the facts, that none of the main reasons for the separate existence of the three appellants was to reduce income taxes. ...
OntCtGD decision
Her Majesty the Queen v. Rupert Folkard, Folkard of Canada Incorporated, Dendor Roto-Sphere Valves Limited, Brooktree Investments Limited and Lome Yacyshyn, [1993] 1 CTC 408
Rupert Folkard, Folkard of Canada Incorporated, Dendor Roto-Sphere Valves Limited, Brooktree Investments Limited and Lome Yacyshyn, [1993] 1 CTC 408 Langdon, J. ... As of January 14, 1993, they have not been forthcoming. In theory, at least, a review of the decision to commit might be possible without those reason; it is, in practical terms, unrealistic considering that the preliminary inquiry yielded 13 volumes of evidence. ... Assuming that the trial is completed by March, 1993, the aggregate time occupied by the case will have been approximately 39 months: 27 months in the Provincial Division, of which nine can be considered institutional delay; and 12 in the General Division, of which I think it would be fair to consider nine months as institutional delay. ...