Search - 报销 发票日期 消费日期不一致

In 1978, the company was newly incorporated and its only business was the operation of the Red Barn on the SW‘/4 of section 29 — the only quarter section described in the lease. ... For its fiscal periods ending the 30th day of June, the company paid to Cochrane and Jerram rents which were allocated between the Red Barn and the Wildlife Park as follows: Red Barn Wildlife Park Total Total 1978 $10,000 $ 0 $10,000 1979 $15,600 0 $15,600 1980 $14,000 $ 5,680 $19,680 1981 0 $25,000 $25,000 1982 0 $25,000 $25,000 1983 0 $25,200 $25,200 1984 0 $25,400 $25,400 1985 0 $21,500 $21,500 1986 $16,700 0 $16,700 For each of the years 1981 to 1985, the operating loss at the Wildlife Park exceeded the profit at the Red Barn by an amount which, on average, was approximately $240,000. ... The company paid and deducted the municipal taxes on the SW / of section 29. ...

Woolworth building for the sum of $1,120,000 by a notarized contract of sale registered on March 11, 1985 under No. 425593; (o) the appellant realized a profit of $275,261 from the sale of March 6, 1985, calculated as follows: Proceeds of disposition $1,120,000 ACB 844,739 Profit $ 275,261 (p) on February 29, 1984, the appellant and 113064 Canada Ltee each purchased an equal share in a building situated at 2469 rue Langelier in Jonquitre (hereinafter referred to as "the Langelier building") for the sum of $531,000; (q) on December 28, 1984, the appellant and 113064 Canada Ltée sold the Langelier building for the sum of $625,000; (r) the appellant realized a profit of $36,082 from the sale of December 28, 1984, calculated as follows: 1/2 proceeds of disposition $312,000 1/2 ACB 276,418 Profit $ 36,082 (s) during the year in issue, the appellant disposed of a third building, situated on rue Massenet, and realized a profit of $5,420; (t) on October 9, 1980, Mr. ... I would receive my profit from the rents — that is, the sublease that would be granted to me would be on the same terms as those I would require from my tenants. ... M.N.R., [1989] 1 C.T.C. 2272, 89 D.T.C. 165; Veltri & Son Ltd. v. ...

A “Rights & Things” return has been filed under subsection 70(2) of the Income Tax Act, to include the deemed receipt of the RRSPs belonging to the deceased taxpayer. ... See also: Western Smallware & Stationery Co. v. M.N.R., [1972] C.T.C. 7; 72 D.T.C. 6036 at 14 (D.T.C. 6041-2) (F.C.T.D.); Gibbon v. ... We also wish to point out that there is no Death Benefit exemption of $10,000 allowable, as erroneously indicated by Supply & Services Superannuation Divi sion. ...

The value of the farm assets in the years 1980 to 1985 as calculated by the appellant are set out in Exhibit A-10 as follows: The value attributed to the cattle inventory is Harding's estimate of approximate value based on ”... the sales that I purchased the animals at, and what the sales were going at on average at that point in time for those type of animals. ... As to the prices of Chianina cattle in 1980 the test they had:... just come out of the late 70’s when everything was on a wild type swing and prices were escalating and had escalated into the 80's...the Chianina cattle specifically had a price levels [sic] where we saw some little increases from 80 to 81 to 82, somewhere in there, but definitely in 83 right down to 85 they not only fell, they absolutely plummeted whereby we saw purebred cattle that at one time were worth, as an example, $10,000.00 go right to a value of $ 1,500.00 to $2,000.00. ... The amount of $ 10,338.87 included in computing the appellant's income for his 1981 taxation year as a loan by Harding Industries to the appellant in the 1981 taxation year is to be deleted; 3. ...

Act- Case Law — Analysis 4.01 Act The principal provisions of the Income Tax Act applicable in the instant appeal are paragraphs 160(1)(a) and (e) and subsections (2) and 248(1) (definition of the word "property"). ... "There is none — moreover, this is why you have an assessment issued with a number, there is no taxation year in question for the recipient" (trans, pp. 90-91). 4.04.3(2) As to the fact that the notice of notification mentions the taxation year 1985 (para. 3.02.6), counsel added: Further, the notice of notification cannot be used to argue that the Minister chose a year, because this is simply a matter of procedure, and if there are clerical errors in the notice this does not fundamentally vitiate the assessment. ... Only subparagraph 160(1)(3)(ii) refers to this, but to specify the amount of tax owed by the transferor of property ”... in respect of the taxation year in which the property was transferred or of any preceding taxation year". ...

.: — This is an appeal from an assessment in respect of the appellant’s 1988 taxation year. ... B & J Music Ltd. (sub nom. B & J Music Ltd. v. The Queen), [1983] C.T.C. 50 (sub nom. B & J Music Ltd. v. Minister of National Revenue), 83 D.T.C. 5074, in which it was held that the taxable income of a “Canadian-controlled private corporation” for the years in which it was not such a corporation and could not thus be entitled to the small business deduction provided for in section 125 of the Act had to be brought into consideration for the purposes of computing the “cumulative deduction account” of that Canadian-controlled private corporation. ...

.: — The appeal of Manac Inc. was heard in the city of Montréal, Province of Quebec, on July 18 and 19, 1995. ... “Similar business” = two manufacturing and processing activities, the one manufactures clothing, the other aircraft engines, same business. In Martin & Company (E.P.) Ltd. v. Minister of National Revenue, (1959), 22 Tax A.B.C. 254, the appellant had operated in the sale of clothing before and after a fire in 1955: before the fire, in the retail sale of women’s clothing and, afterward, in the manufacturing and wholesaling of women’s, then men’s clothing. ...

In my view, the situation is more akin to that which existed in Olympia Floor & Wall Tile (Que.) ... Another test developed by the Privy Council in British Insulated & Hel- sby Cables Ltd. v. ... In this respect the situation differs from that in British Insulated & Helsby Cables Ltd., supra, in which the expenditure was used to create a permanent pension fund for the employees of that company. ...

Analysis and conclusions In my assessment of the evidence, I gave much credence to what counsel for the respondent had to say and little if any to what the appellant had to say, since — and I say this regretfully — the appellant’s statements are not reliable. ... M.N.R., 64 D.T.C. 5332; Vineland Quarries & Crushed Stone Ltd. v. ... The Supreme Court of Canada, in its majority judgment, per McLachlin J., stated the following regarding a new basis for an assessment: …] agree with Bastarache, J. that the Minister’s argument that the Bank sold depreciable leasing assets or was otherwise liable for recapture of capital cost allowance pursuant to s. 88(1) of the Income Tax Act, R.S.C. 1952, c. 148, as amended, raised for the first time in this Court, cannot be entertained. ...

Levert); — portrait of Dr. Adrien Sarens, pastel, 25 inches by 19 inches, sold for $400 at the Hôtel des Encans de Montréal on April 7, 1992; and — portrait of a man, 14 inches by 10 inches, pencil crayon, sold for $175 at Fraser-Pinney’s on November 24, 1993. ... He also admitted that the subject of the painting in question was a pastoral scene and that oil paintings of pastoral scenes had sold at Fraser Bros. auctions in Quebec at the following prices: • in December 1979, “Cattle in a Field”, 11 inches by 9 inches, $375; [5] and • on March 12, 1987, “Pastoral Scene”, 18 inches by 24 inches, $650. [6] Mr. ... Tremblay to provide him with receipts for the 1988, 1989 and 1990 taxation years for the same amounts — $11,000 for himself and $2,750 for his wife each year — in exchange for payments corresponding, minus the tax on the paintings, to 25 percent of the receipts that were made in two instalments: the first on March 1 and the second on June I of the following year. ...