Search - 枣庄市市中区 智博公考 地址 电话

Of this amount the payments made to Lamontagne & Lamontagne were again dropped by the appellant as were amounts totalling $950 paid to Eric M Lack, Notary, and to the firm of O'Brien, Hall & Nolan. In issue was an amount of $1,964.23 in Canadian currency paid to Hamburger & Green, Counsel lors at Law. ... Exhibit A- 7 is a bill for $600 from O'Brien, Home, Hall, Nolan, Saunders, O'Brien & Smyth, Barristers & Solicitors, and deducted by the appellant, $200 of which was disallowed because it dealt with the St Felicien project. ...

A large insurance broker, Thomason & Saunders, approached Clarkson, Gordon & Co, Trustees in Bankruptcy, with respect to the purchase of the list of customers and negotiated with one Donald Gardner, CA, of the bankruptcy division of Clarkson & Gordon, who was appointed official Trustee in Bankruptcy as a result of a Proposal filed on February 4, 1975. ... There was a subsequent letter, however, written on April 22, 1975, on Hugh & McKinnon Ltd letterhead, with the knowledge and approval of Mr Davidson, whereby the people on the customer list were again contacted and requested to direct their inquiries to Mike and Brian “now located at Hugh & McKinnon Ltd, 5678 — 176th Street, Surrey, BC”. ... At 730 and 6447 respectively, Collier, J states: In my opinion, when one views the “practical and commercial aspects”* [1] of this purchase, the plaintiffs were in reality acquiring, or endeavouring to acquire, an opportunity for potential future customers or business — the trade of the clients of C F Graves & Co. ...

Station Canada & Gulf Terminal Inc v. Minister of National Revenue, [1981] CTC 2044 Roland St-Onge [TRANSLATION]:—The appeal of Station Canada & Gulf Terminal Inc came before me on May 22, 1980 in Quebec City, Quebec. ... Representing the firm of Ménard, Marsan & Associés of Rimouski, Mr Ménard determined a valuation day or “V-Day” value of $0.32 per square foot. The witness Jacques Sauriol, of the firm of Leroux, Beaudry, Picard & Associés Inc, set the value at $0.265 per square foot, without taking improvements into account. ...

Station Canada & Gulf Terminal Inc v. Minister of National Revenue, [1980] CTC 2805 Roland St-Onge:—L’appel de la compagnie Station Canada & Gulf Terminal Inc est venu devant moi le 22 mai 1980 dans la ville de Quebec (Quebec). ll s’agit de déterminer la valeur d’un terrain au 31 décembre 1971 afin de connaître le montant du gain en capital pour l’année d’imposition 1975. ... Représentant la firme Ménard, Marsan & Associés de Rimouski, monsieur Ménard a déterminé une valeur au jour d’évaluation, ou “V-Day” de $0.32 le pied carré. Le témoin Jacques Sauriol de la firme Leroux, Beaudry, Picard & Associés Inc, sans tenir compte des améliorations, a fixé une valeur de $0.265 le pied carré. ...

John Crosier, Lucille E Crosier, Albin Trella, Elizabeth Trella, Victor Prousky, Morris Prousky, 233482 Investments Limited, T Caravaggio & Son Limited, Manfred Feldt, Jean Mary Haschyc, Mendel Goldstein, Harry Teperman, David Irving Teperman, Burstein Bag Limited, Burstein Bag Limited v. ... The following schedule sets out the basic particulars of the property interest of the appellants: Property Year Appellants Appellants Karopa Hilltown 1974 John Crosier X 1974 Lucille E Crosier X 1974 Albin Trella X 1974 Elizabeth Trella X 1974 Victor Prousky X 1974 Morris Prousky X 1975 233482 Investments Limited X 1975 T Caravaggio & Son Limited X 1974 Manfred Feldt X 1974 Jean Mary Haschyc X 1974 Mendel Goldstein X 1974 Harry Teperman X 1974 David Irving Teperman X 1974 Burstein Bag Limited X 1975 Burstein Bag Limited X The following information directly relevant to the appellant Burstein is common to all appellants with respect to either one or the other parcel of real estate as indicated above: —The appellant held interest in two joint ventures known as Hilltown Developments Ltd (“Hilltown”) and Karopa Enterprises Ltd (“Karopa”); —The subject assets of these joint ventures were two pieces of raw land abutting each other in the Town of Oakville near the border line with the City of Mississauga; —The original participants and their respective percentage interests of Karopa were as follows: —Shortly after the purchase of the Karopa Property, Doug Roher and Lou Sherriff, the beneficial owners of K Roher Construction Limited and Lyrad Construction Limited respectively, which corporations in partnership owned Briar Developments, declared personal bankruptcy and thereafter Briar Developments ceased its participation in Karopa; Briar Developments (Roher & Sherriff) 29.7% Burstein Bag Limited 26.9% Crosier 1.4% Goldstein 1.7% McGuigan & Feldt 5.2% Prousky (Victor & Morris) 2.3% Trella (Elizabeth & Albin) 5.9% Warwick 11.2% Welta Wool.2% Feldstein 5% Flishlek.3% Rotsteins.3% Steiglan 6.6% Tomco 1.0% 233482 Investments Limited 7.7% 100.0% UUIJ I, IvVV, (“Karopa”) for $832,742.00 satisfied as follows: Cash $245,207.97 29.4% 1st Mortgage 301,867.03 36.2% 2nd Mortgage 50,750.00 6.1 % 3rd Mortgage 234,492.00 28.2% Taxes, etc 425.00.1 % $832,742.00 100.0% — During 1972, other participants of Karopa also encountered financial difficulties, and a reorganization occurred with the remaining participants taking over the vacated syndicate participation, the result being that the eventual composition of the Karopa joint venture was as follows: Burstein Bag Limited 35.720% T Caravaggio & Son Ltd 17.860% 233482 Investments Ltd 10.716% Jean Haschyc 5.706% Elizabeth Trella 5.706% Albin Trella 3.224% Joseph Rajca Jr 3.224% Mendel Goldstein 3.572% Manfred Feldt 3.572% Prousky (Victor & Morris) 3.556% John Crosier (husband & 1.786% Lucille Crosier wife) 1.786% Dorothy McGuigan 1.786% Beverly Young 1.786% 100.000 % Limited for a consideration of $1,901,664, realizing a gross profit of $1,068,922. ... No commission was paid by the group on the sale of the property. — In light of the whole history of the property, the amount received by the appellant as proceeds of disposition of its interest in that property was a Capital receipt. — In any event, the gain attributable to the portion of the appellant’s interest in the property that was acquired when Briar withdrew from the group was a Capital gain in that the appellant was forced to acquire that interest in order to protect its investment in the property. ...

Shultup Management & Investments LTD v. Minister of National Revenue, [1972] CTC 2655 The Chairman (orally):—This is an appeal by Shultup Management & Investments Ltd, a company incorporated under the laws of the Province of British Columbia, against a Notice of Reassessment by the Minister for the taxation year 1962. ... Zielinski went to the specified location and staked the area of the old workings, and continued on to stake a total of 14 claims, during the course of which assignment he managed to personify the classical mind’s-eye picture of a prospector chipping away at outcroppings and deciding by “an eyeball assessment” — a talent gained through years of experience — whether or not a particular area was worthy of staking and recording or not. ... I have read the evidence in great detail, and I find nothing in the line of fact that would allow me to infer that the appellant company was the person who made the arrangement — or the corporation that made the arrangement — with Cohen as contemplated by subsection 83(3). ...

Rosenhek & Machlovitch, Suite 1700 — One Westmount Square, in the City of Westmount, Province of Quebec, on March 17th, 1977, or on such earlier or later date as may be agreed upon by the Purchaser and the Vendor. ... Findings The position of counsel for Mr Senecal is a rational one — that Senecal simply would not have accepted $50 for stock worth some $28,850 — and counsel made a convincing case for the acceptance of his position. ... Whatever else may arise from an examination of this matter, his claim to a capital gain is unfounded — the $26,450 at issue was not for the sale of his stock — it is salary income to Senecal in the year 1977. ...

Veuve Clément Bouchard & Euclide Bouchard es qualité v Diane Lepire, [1974] CA 616; 17. ... Union Insurance Society of Canton Limited & André Arsenault, [1961] S.C.R. 766; 22. ... Eugène Lagacé <& George Lagacé v MNR, [1968] CTC 98; 68 DIC 5143; 41. ...

During the 1966 to 1972 taxation years Marquis Ltée and Beaudet & Fils Inc (hereinafter “Beaudet Inc”) founded and operated a company known as Beaudet & Marquis Enrg, which became Beaudet & Marquis Inc on January 1, 1973; 4. ... Re Beaudet & Fils Inc (“Beaudet Inc”) 2. During the 1969 to 1972 taxation years the applicant was involved in the construction field; 3. During the 1966 to 1972 taxation years Marquis Ltée and Beaudet Inc founded and operated a company known as Beaudet & Marquis Enrg, which became Beaudet & Marquis Inc on January 1, 1973; 4. ...

D R Milne & Company Limited v. Minister of National Revenue, [1979] CTC 2294, 79 DTC 334 M J Bonner:—The issue in this appeal is whether the sum of $28,850, being the price fixed by an agreement dated August 1, 1973, between the appellant and Black & Armstrong Limited (hereinafter “Black”) for the purchase by the appellant of, inter alia, an “Expiry List”, was a current outlay or a payment on account of capital. ... Black covenants and agrees that it will prevent any use of the name within the Province of Manitoba “Black & Armstrong Limited” by any other person, firm or corporation in connection with insurance business and will take all action necessary at the expense of Hammarstrand & Greeniaus (or in the opinion of Hammarstrand & Greeniaus, desirable) to prevent such usage. ... However, the ultimate business outcome cannot affect the characterization of the transaction (see Her Majesty the Queen v Baine, Johnstone & Company Limited, [1977] CTC 556; 77 DTC 5394). ...