Search - 报销 发票日期 消费日期不一致

The decisions of Amden were made by the Appellant and he was its controlling mind.... p) At all times material to this appeal, more particularly from 1989 to 1992, the Appellant carried on the profession of an architect under the name, style and firm, Gordon Atkins & Associates. q) The Appellant had, in the course of years, acquired skill and expertise with regard to processing applications for the subdivision of land and also of supervising the construction of facilities such as road ways, water, power, landscaping etc. r) The Appellant participated in many subdivisions in respect of different lands at times previous to 1989. s) On June 15, 1987, Amden entered into an agreement with Wood (the "Contract") for the benefit of the Appellant in respect of a parcel of land owned by Wood in extent about 87.5 acres and legally described as the South-east quarter of Section 24, Township 24, Range 3, West of the Fifth Meridian (the "Land). ... " As he and Amden's services were used, he "... felt secure that my land bank was growing. ... ".. W " The struck out portion indicates that, at the very least, Mr. ...

Pillo, testified — and I accept his testimony — that it was at the request of the revenue auditor Mr. ... Bowman" J.T.C.C. [1]               See McNabb Family Trust v. The Queen, 98 DTC 6001 (F.C.A.) reversing 96 DTC 6425 (F.C.T.D.). [2]               But see: Driedger on the Construction of Statutes, Third Edition, page 246. ...

(the "payer") was not insurable within the meaning of the Unemployment Insurance Act (now the Employment Insurance Act) (the " Act ") since there existed between the appellants and the payer no contract of service within the meaning of paragraph 3(1)(a) of the former Act and paragraph 5(1)(a) of the new Act during those periods. ... (A-1470-92), the Federal Court of Appeal describes the function of a Tax Court of Canada judge, and I quote: "... ... Solange Delorme's Testimony [67] This witness acted as insurance officer in the case of the worker Paraskevi Hadjinikita, whom she contacted on June 17, 1996. [68] The witness related to the Court the information which the appellant Paraskevi Hadjinikita gave her in a telephone conversation on June 17, 1996. [69] This information appears in Solange Delorme's report (Exhibit I-4) and reads as follows: [TRANSLATION] "- She was an apartment building office clerk for eight months.- There were two apartment buildings, but she does not know how many apartments.- She worked on the first floor, but does not know what apartment.- She answered the telephone, prepared the invoices and translated brochures from Greek into French.- She had a typewriter at home and took work home.- She was not in the office all day.- Most of the calls were for Jimmy Tsakalis, Mickael's brother.- She never had any dealings with the tenants.- Jimmy was her boss.- She does not know whether there were other employees.- She was paid by cheque, once a month.- She does not know who signed the cheques and there were no cheque stubs.- She does not know whether deductions were made.- She had virtually nothing to do and it was unfulfilling employment.- She does not remember whether she got the job by responding to an advertisement in the Greek newspaper, an announcement on the Greek radio or an advertisement in a convenience store. ...

.: — The appellant appeals from reassessments made against him on a net-worth basis for the 1988, 1989, 1990 taxation years. ... Also this appears in a number of places “KP & friends”. It is related to such things as framing, roofing, bricklaying and labour. ... Now also in the Mastercard statements that I received, there are a number of — many items in the Mastercard statements that indicate a lot of those things would have been business expenses such as purchases made: Bytown Lumber; Beaver Lumber; Home Hardware; Rentalex and they were counted as personal. ...

Cullen J. commented on the state of the jurisprudence as follows at page 99 (D.T.C. 6339): The cases prior to Day & Ross Ltd. v. ... Alex Von Glehn & Co., 12 T.C. 232. In Day & Ross, Dube J. seemed to take a more liberal view of the deductibility of fines under paragraph 18(1)(a) of the Act. ... Moreover, I think that the over quota production of eggs is no more outrageously against public policy than was the violation of the provincial highway weight restriction laws as decided in the case of Day & Ross Ltd. v. ...

Derek Darling (of the firm Healy & Darling), an accountant acting for Agri-Can at the request of Mr. ... Denni Cheng, did not work for the firm Healy & Darling before October 22, 1984; [Translation.] ... McMechan & Bourgard, Tax Court Practice, Carswell, 1994, pages 900-01 (Failure to call witness). ...

The basic reason given for selling the property is that the three brothers were overwhelmed by the magnitude of the profit — some $550,000 minus expenses related to acquisition and disposition — in relation to the size of their investment and the time factor, which was a lapse of some 9-1/2 months. ... It is something to be weighed along with the other relevant circumstances: O & M Investments Ltd. v. ... Such a basis was disapproved of in the Reading & Bates case ((1986) 2 F.T.R. 241 at page 264). ...

The appellant, Alexander “ Bill” Laxton testified he purchased his Gambler Island strata lot in 1980 on the basis that farm losses would be deductible and the marketing of the lots had been done on the basis of them being a tax shelter. ... In 1982, loss attributable to the farming operation was in the sum of $19,627.13 which divided by 66 — the total number of strata lots — created a per unit loss of $297.38. ... The appellants faced further difficulty in that the total revenue produced from farming within the definition of the Income Tax Act was divided into 66 parts — with the developer continuing to receive a portion of the proceeds as a consequence of retaining unsold lots. ...

The following table illustrates these purchases: Date of Purchase Date of Sale Price Property Purchase Price Sale 3080, rue Bolduc, Montréal 6-5-82 $650,000 7-12-84 $ 785,000 2665, rue Frontenac Montréal 20-3-85 $975,000 4-11-85 $1,165,000 2154, rue Dollard, Longueuil 15-4-86 $565,000 22-5-86 $ 690,000 On November 25, 1986, the appellant, with other people, purchased a 24- apartment building located on rue St-Georges in Ville Lemoyne for $802,400, which was resold on December 30, 1987 for $1,085,000. ... M.N.R., [1982] C.T.C. 2668, 82 D.T.C. 1683 (T.R.B.); Martin & Frères Ltée v. M.N.R. (1955), 13 Tax A.B.C. 158, 55 D.T.C. 363 Counsel for the respondent referred to the following cases, inter alia; Racine, Demers & Nolin v. ...

Lang, Mich- ener, Cranston, Farquharson & Wright, First Canadian Place, Toronto, Ontario, at 2:00 pm on the 4th day of January, 1977 or at such other place and time as shall be fixed by agreement of the parties (the “Closing Date”) but with effect as of the commencement of January 1, 1977 (the “Effective Date’’). ... In Furnivall v Coombes, 5 M & G 736, the effect of the proviso, if effect was to be given it at all, was of necessity to relieve the covenantors from any sort of personal obligation, a result held to be obviously inconsistent with the intention of the transaction. ... Furnivall v Coombes (1843), 5 Man & G 736, is an illustration of the former case: William v Hathaway (1877), 6 Ch D 544, is an illustration of the latter. ...