Search - 德国民法典第1993条

Her Majesty the Queen, [1993] 1 CTC 231, 92 DTC 6460 Lefebvre, S.P.:—This Court orders that the plaintiff's appeal with respect to the 1980 taxation year be and is hereby allowed, without costs to either party, and that the reassessment for the plaintiff's 1980 taxation year be and is hereby referred back to the Minister of National Revenue for reconsideration and reassessment on the following basis: (a) That, of the amount of $214,329.90 incurred by the plaintiff as capital costs in 1980, $46,943 was qualified property giving rise to a deduction for an investment tax credit pursuant to subsection 127(5) of the Act; This Court further orders that the plaintiff's appeal with respect to the 1981 taxation year be and is hereby dismissed without costs to either party. ...

MNR, 93 DTC 939, [1993] 2 CTC 2370 (TCC) Christie, A.C.T.C.C.J.:— The year under review is 1984. ... The operation has therefore none of the essential characteristics of an investment, it is essentially a speculation. [3] In the course of argument on January 14, 1993, counsel for the appellant cited Loewen v. ... Loewen, [1993] 1 C.T.C. 212, 93 D.T.C. 5109. The appeal is dismissed. ...

Minister of National Revenue, [1993] 2 CTC 342, 93 DTC 5455 Hugessen, Linden, Robertson, JJ.A.:— This section 28 application seeks to review and set aside a decision of the Tax Court of Canada made under subsection 231.4(2) of the Income Tax Act, R. ... Canada, [1993] 1 S.C.R. 416, [1993] 1 C.T.C. 111; M.N.R. v. Kruger Inc., [1984] C.T.C. 506, 84 D.T.C. 6478 (F.C.A.)), such an attack cries out to be made. ...

Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2458 Watson, D.J.T.C.C.:— This appeal was heard at Quebec City, Quebec, on February 11, 1993, under the informal procedure. ... As evidence in support of the claimed expenses $1,575 for a “training course”, the appellant produced as Exhibit A-1 a letter from her brother, François Morency, dated January 22, 1993 which reads as follows: Dear Ann, At your request, and for confirmation to the tax authorities, this is to confirm that in 1988 I was the secretary of the Canadian Association of Financial Planners and that Ann Morency and two of her colleagues participated in the following activities of the association: Three people: Financial planning course at $435 per person $1,305 Two sets of eight tickets for business luncheons at $110 per set 220 Total: $1,525 I hope that this will be to your satisfaction. ...

Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2486 (Informal Procedure) Christie, A.C.T.C.C J. ... Canada, [1993] 2 C.T.C. 2480 (T.C.C.). In that appeal, as in the appeal at hand, Gustave Tasch, John Donelian and the museum were important factors. ... Canada, [1993] 2 C.T.C. 2475 (T.C.C.). The appellant is an obstetrician. ...

Her Majesty the Queen, [1993] 2 CTC 2963 Hamlyn, T.C.C.J.:— This is in the matter of Mike Milliken the appellant and Her Majesty The Queen the respondent. It's an informal procedure appeal dated June 22, 1993 with respect to the appellant's 1988 taxation year. ... And from McMechan and Bourgard's Tax Court Practice, 1993, at page 930 in relation to Wolff, supra, the following is stated: The Crown is not an individual with whom a comparison can be made to determine whether subsection 15(1) violation of the Charter has occurred. ...

After a status hearing held in August of 1992 the appeal was scheduled to be heard on March 3, 1993 and continuing for a total of three days. ... The trial commenced on May 31, 1993 and on the sixth day, after several witnesses were heard, including various experts, this Motion was presented to the Court. ... Finally, on May 31, 1993, the first day of the trial, counsel for the appellant stated as follows (Supp. ...

The Queen, 93 DTC 5120, [1993] 1 CTC 226 (FCA) Hugessen, J.A.:— We are all of the view that the learned trial judge committed no error when he looked at all the circumstances surrounding the making of the agreement between the appellant and his wife in order to determine that the payment of $45,000 and the three further payments of $50,000 each, spread over a little more than two years, were lump sum payments and not “allowance... for the maintenance" of the wife. ...

Devor, 93 DTC 5098, [1993] 1 CTC 142 (FCA) Mahoney, J.A.:—In refusing to strike out the statement of claim, the learned trial judge relied on the decision of one of his colleagues in Optical Recording Corp. v. ...

Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2192, 93 DTC 563 Taylor, T.C.C.J. ...