Search - 德国民法典第1993条

The appellants’ request for what is admittedly discretionary relief was submitted to the Minister in October 1993 and was rejected by him in November of that year. ... This new subsection was repealed in 1993, by virtue of subsection 127(2) of S.C. 1993, c. 24. ... The limitation, if there is any, must be found in subsection 127(5) of the 1993 legislation. ...

A second audit was carried out covering the years 1990, 1991, and 1992, this audit being completed by January 11, 1993. ... The letter of July 16, 1993 went on to consider whether the appellant was engaged in political activities. ... Young, [1993] 4 S.C.R. 3 (S.C.C.); Droit de la famille- 1150, [1993] 4 S.C.R. 141 (S.C.C.). ...

.:— We have not been persuaded that any reviewable error has been made by the learned Tax Court judge in coming to his judgment of March 16, 1993, whereby the applicant’s appeal from an assessment to tax for the taxation year 1988 was dismissed. ...

The issue is whether the appellant had a reasonable expectation of profit from the operation of his Amway distributorship in 1993 and 1994. [2]                Although the appellant has pointed out factual errors made by the Tax Court Judge, and the respondent concedes at least one material factual error, the appeal is to be decided on the proper application of the reasonable expectation of profit test established in [1978] 1 S.C.R. 480 "> Moldowan v. ... The Minister in his pleading did not make any assumption about personal benefit and the evidence is much too scant to warrant any adverse finding to the appellant based on personal benefit. [4]                The basis of the Tax Court Judge's finding that the appellant had no reasonable expectation of profit in 1993 and 1994 was: 1.            ... Taken together, these prevented the Appellant from having a reasonable expectation of profit in 1993 and 1994. [5]                With respect, I am of the opinion that the analysis conducted by the Tax Court Judge amounted to second-guessing the business acumen of the appellant which is not the place of the Courts. ...

Justice Teskey on August 3 and September 14, 1999, regarding the Minister's reassessments of his 1993 and 1994 taxation years, were wrongly decided. [5]                Specifically, according to the appellant, both Mr. ... Justice Bowie had failed to properly determine the correct amount of his purchases for the 1993 and 1994 taxation years. He argued that there was a discrepancy of $10,500 for the 1993 taxation year and $6,000 for the 1994 taxation year between the audits performed for those years by the GST auditor and the income tax auditor, and that there could be no doubt that the figures arrived at by the GST auditor (the higher figures) were correct. ...

IT IS ORDERED that this appeal is allowed, without costs, the order of the Tax Court of Canada is set aside and the time for filing the reply to the notice of appeal in the Tax Court of Canada is extended to July 15, 1993. ...

The application will be dismissed, in relation to the 1993 taxation year. ...

The Overtime Balance arose from a Memorandum of Understanding attached to a collective labour agreement signed by GM in 1993 (the MOU). ... The Special Canadian Contingency Fund will be continued during the term of the 1993 Master Agreement. 2. ... For example, article 5 of the MOU provides as follows: As of the end of the 1993 Master Agreement period, the parties would negotiate the usage of any accrual then remaining in the Special Canadian Contingency Fund. ...

Norwood for 1991, 1992 and 1993 as shareholder appropriations. Penalties were assessed against Mr. ... Norwood's income for 1992 and 1993 as shareholder appropriations. ... Norwood appealed the 1991, 1992 and 1993 reassessments to the Tax Court. ...

Nonetheless, in 1993 it still employed seventy people. [8]      Abel's bank, the Canadian Imperial Bank of Commerce, expressed concern over the company's April 1993 financial statement. ... Abel had reached the limit of its credit line by either the fall of 1992, or early in 1993. ... The formal letter of refusal from the bonding company was dated August 30, 1993. ...