Search - 枣庄市市中区 智博公考 地址 电话

In computing his net income for his 1974 to 1977 taxation years, the Appellant claimed in deduction of his income capital cost allowance (class 8) in the following amounts; 1974 — $5,555 1975 — 4,739 1976 — 3,906 1977 — 5,071 4. ... In making the said reassessments, the Respondent disallowed in part the deduction of capital cost allowance (class 8) as claimed by the Appellant in the following amounts; Amounts Amounts Amounts Year Claimed Allowed Disallowed 1974 $5,555 $ 981 $4,574 1975 4,739 1,080 3,659 1976 3,906 979 2,927 1977 5,071 2,730 2,341 and determined the Appellant’s income in the following manner; 1974 1975 1976 1977 $ $ $ $ Toral income previously assessed 27,636.00 35,874.00 40,112.00 39,096.00 Add Personal portion of automobile expenses 1,450.50 11,594.44 1,729.01 3,000.00 Taxable capital gain — 1,323.50 1,323.50 1,324.00 CCA disallowed 4,574.00 3,659.00 2,927.00 2,341.00 Revised total income 33,660.50 42,450.94 46,091.51 45,761.00 5. ...

Also filed were statements of income and expenses: Exhibit A-11: Buildings owned by appellant — 1977 — Income — $272,000. Exhibit A-12: Warehouses — 1979- gross income — $7,185,000 — — net income — $2,785,000. He explained that the income from the warehouses was much greater than that from the apartments and that they represented 60% of the invested capital; he further explained that in 1975, a very active year, supplementary letters patent had been obtained in order to confirm what had become a reality, namely, their vocation as leasing specialists, and that a new company, Roussin & Frères Ltée, was being set up for the sole purpose of going into the construction business. ...

In assessing the appellant for his 1970, 1971, 1972 and 1973 taxation years, the respondent relied, inter alia, on the following presumptions of fact: (a) during the years in question, the appellant operated a transport business and was a partner in the operation of a bar in the city of La Salle; (b) the appellant did not file tax returns for the years in question within the time limits specified in the Income Tax Act; (c) on May 8, 1975, the appellant was required to file tax returns for the said years; (d) following this requirement to file, the appellant filed returns for 1970 and 1971 on July 4, 1975 and returns for 1972 and 1973 on July 22, 1975; (e) the appellant reported the following amounts of taxable income in computing his income for each of these years: Year Taxable amount 1970 $ 9,068.50 1971 $23,911.32 1972 $53,184.20 1973 $55,833.81 (f) the taxpayer failed to include his share of the income from the operation of the bar in the taxation years 1970 and 1971; $3,577.98 for 1970 and $7,616.94 for 1971; (g) the taxpayer therefore made a reconciliation of the appellant’s income and determined that his taxable income for the years in question was as follows: Year Taxable amount 1970 $11,546.48 1971 $29,828.26 1972 $53,184.20 1973 $55,833.81 (h) in a notice of assessment dated February 13,1976, the respondent applied a penalty under s 56(1) and s 163(1) of the Act, on the amounts of tax payable for each of the years in question: Year Tax payable Penalty (50%) 1970 $ 1,770.97 $ 885.48 1971 $ 5,829.06 $ 2,914.53 1972 $13,770.87 $ 6,885.44 1973 $14,695.09 $ 7,347.54 (i) the appellant wilfully attempted to evade payment of the tax payable by him by failing to file tax returns for the years in question. ...

Sale No 2 — Martin to Woodlands — sold in April 1969 for $340,000 — 105 acres; 2. Sale No 4 — Campagnaro — sold in November 1969 for $350,000 — 99 acres; 3. Sale No 6 — Rutherford — sold in December 1973 for $310,000 — 43 acres. ...

Among other things, these notices show the following figures: Additional In- come Additional tax Penalties 1969 $27,824.89 $ 8,017.09 $1,522.00 1970 28,608.68 8,168.65 1,553.08 1971 30,568.18 8,762.04 1,685.01 1972 30,568.18 9,545.53 1,909.11 1973 18,419.29 4,827.18 965.44 1974 21,946.44 5,646.67 1,129.34 $157,935.60 $44,967.16 $8,763.98 3.05 At the beginning of the hearing, the respondent also filed en Hasse (Exhibit I-2) the opening balance sheet at December 31, 1968 and the closing balance sheet at December 31, 1974 with the calculation of capital and various schedules all of which formed the basis of the various assessments: Mr Gabriel Juteau Revised Statement of your Assets and Liabilities at December 31 1968 1974 ASSETS Current assets: Account receivable $ 775.20 $- Bank BCN no 1708 3,214.14 3,004.26 Bank BOM c/a — 122.97 Inventory 2,000.00 — $ 5,989.34 $3,127.23 Investments: Advance to Incarpool Inc. $- $41,647.66 Incarpool shares — 990.00 Term deposit BCN — 27,000.00 Term deposit BOM — 10,200.00 Bonds “Schedule 9” — 60,056.00 Shares “Schedule 8’’ — 13,109.00 $ — $153,002.66 Net Fixed Assets: Commercial land $20,000.00 $ 20,000.00 Commercial building 8,000.00 8,000.00 Chrysler automobile 3,800.00 5,886.00 Dodge 1971 Camper Truck — 3,/00.00 Ford Truck 1968 2,800.00 2,800.00 Camper Box (hand-made) 500.00 — Residence: 34, rue des Erables 12,300.00 12,300.00 Land: 34, rue des Erables 2,000.00 2,000.00 $49,400.00 $ 54,686.00 Total Assets $55,389.34 $210,815.89 LIABILITIES Mortgage on residence $ 5,847.39 $ 3,160.11 Balance of sale price on comercial land $12,000.00 — Total liabilities $17,847.39 $ 3,160.11 CAPITAL $37,541.95 $207,655.78 Total Capital and Liabilities $55,389.34 $210,815.89 Durette/rI Section 41-1 Room 1047 Montreal, February 15, 1977 Schedule ‘1’ 3.06 At the beginning of the hearing, the appellant put forward a number of points of disagreement (hereafter appearing under the letters A to K) with certain figures on the respondent’s opening and closing balance sheets. ... This list reads as follows: Shares Iso Mines $ 7,170.00 Neonex $ 3,641.00 Pan Can Petro $ 1,480.00 Great Northern Capital $ 1,215.38 Canadian Superior Oil $ 7,781.25 Inland Chemical $ 4,357.89 Vascan $ 4,515.01 Kirkland Townsite $ 4,383.99 Revenue Properties $ 4,410.00 Miscellaneous (approximate) $20,000.00 $58,926.64 3.24 Part of Exhibit A-5 was a supporting document issued by Doherty Roadhouse & McCuaig, a member of the Canadian Association of Stockbrokers. ... The inventory at the end of 1968 would therefore amount to $15,000 ($2,000 + $5,500 + $7,500). ...

Minister of National Revenue, [1981] CTC 2302, 81 DTC 288 D E Taylor: [Translation] —This appeal which was heard in the city of Montreal (Quebec) on June 11, 1980, was brought following tax assessments in which the Minister of National Revenue refused to allow the taxpayer to deduct the following amounts, which he had paid to his wife or ex-wife Mrs Lucille Dubois, as alimony: 1970 — $5,560 1971 — $6,260 1972 — $6,260 1973 — $6,260 1974 — $4,160 1975 — $5,075 The only point at issue is whether these amounts were paid in accordance with a written settlement and/or a written agreement. ... This letter and agreement, which were produced as exhibit 1-1, read as follows: BARD, L'HEUREUX, PHILIPPON & TOURIGNY AVOCATS — BARRISTERS SAM SCHWARZ BARD, QC SUITE 309 CLAIRE L’HEUREUX-DUBE FLORENCE BUILDING JACQUES PHILIPPON 771 EAST, RUE ST-JOSEPH CHRISTINE TOURIGNY QUEBEC (2) CANADA June 26, 1969 Mrs. ... Yours truly, BARD, L’HEUREUX, PHILIPPON & TOURIGNY By: (Signed) Cl CLD/mp AGREEMENT AGREEMENT entered into in Quebec City, this day of June, 1969 BETWEEN DAME LUCILLE CHAMBERLAND, hereinafter referred to as, THE WIFE AND MR JACQUES CHAMBERLAND, hereinafter referred to as THE HUSBAND 1. ...

During the 1975 taxation year, the employer reimbursed an amount of $735.42 to the appellant. 3.06 In filing his income tax return for the 1975 taxation year, the appellant claimed $388.88 as deduction computed as follows: Capital Cost Allowance: $2,541.00 Insurance & Registration: $180.00 Gasoline: $640.80 Oil & Lub & Filters: $ 84.00 Repairs & Maintenance: $180.97 $1,085.77 $3,626.77 Business Miles 4137 x $3,626.77 = $1,124.30 Total Miles 13,352 Less Reimbursement from Consumer and Corporate Affairs $ 735.42 Claimed $ 388.88 The amount of $640.80 for gasoline was calculated as follows on the basis of 15 miles per gallon and 0.72¢ per gallon: 13,352 = 890 x 0.72 = $640.80 15 3.07 Upon reassessment dated November 1, 1976, the respondent disallowed the amount of $388.88. 3.08 A notice of objection was filed on November 23, 1976. 3.09 The respondent answered on March 24, 1977, to confirm the reassessment. 3.10 The appellant lodged an appeal before the Tax Review Board on April 18, 1977. 4. ...

Track and $ 6,000 $ 4,500 100 100 $ 6,000 $ 4,500 judge’s quarters 1,200 1,200 100 100 1,200 1,200 2. ... Inside track 40,000 (0.05) $ 2,000.00 (0.05) $ 2,000 5. Access road 21,000 (0.10) $ 2,100.00 (0.05) $ 1,050 6. Parking 100,000 (0.08) $ 8,000.00 (0.10) $10,000 7. 6” pipe aqueduct 1,100 (long) (5.50) $ 5,500.00 (2.08) $ 2,288 8. 4” inch pipe aqueduct 1,200 (long) (4.50) $ 5,400.00 (2.44) $ 2,684 9. 6’ high wood fence 4,000 (lin)(50%) (2.00) $ 4,000.00 (2.00) $ 4,000 10. 4’ high fence—sletcoh 336 (lin) (4.00 x 90%) $ 12.10 (2.71) $ 910 11. ...

Yours truly, (Signed) Jean-Paul Dufour for the chief of Audit JPD/lh Lachapelle, Bruzzésé & Cie PIERRE LACHAPELLE ROBERT BRUZZESE, BCOM, CA Registered Public Accoutant Chartered Accountant 2103 Jean Talon St East Montreal tel: 721-9771 March 10, 1977 Revenue Canada, Taxation National Revenue Building 305 Dorchester Boulevard West 5th floor, section 51(4) Montreal, Quebec H2Z 1A6 Attn: Mr Jean-Pau I Dufour SUBJECT: ROBERT BRUZZESE Tax returns 1972-1973-1974 Dear Sir: I acknowledge receipt of your letter of February 24, 1977. ... Yours truly, (Signed) Jean-Paul Dufour for the Chief of Audit JPD/lh REGISTERED May 19, 1977 Mr Robert Bruzzese Jean-Paul Dufour 9029 Boisonnault Section 51-4 St-Léonard, Que 5th floor H1P 2X3 Tel: 283-5326 Dear Sir: Subject: Your tax returns for 1972, 1973 and 1974 Further to our letter of February 24, 1977, you have not sent us your supporting documents as requested and we have consequently verified your tax returns for the above-mentioned years, to which we intend to make the following changes: (A) Income from self-employment 1972 1973 1973 1974 1974 Expenses claimed $8,893.33 $10,080.75 $36,671.94 Less: Automobile expenses (1) 549.92 1,756.18 2,747.51 Rental expenses (2) — 1,105.00 — Stationery and printing (3) 210.31 644.34 964.25 Advertising and promotion (4) 71.21 199.87 388.32 Office maintenance and repairs (5) — — 573.10 CCA on furniture and equipment (6) — 878.88 1,024.30 Expenses disallowed $ 831.44 $ 4,584.27 $ 5,697.48 Expenses allowed $8,061.89 $ 5,496.48 $30,974.46 (1) 1973 and 1974 capital expenses disallowed. ...

Bank Records — Letter from Bank — Account Agreement — Hypothecation of Collaterals — Loan Authorizations 1979-81 — Application for Credit — Signing Authorities 7— Demand Loan Ledger F. ... Copies of Minutes — Regular Meeting H. Copies of Minutes — Annual Meeting I. ... Financial Plan — Proposal — Tabulation K. Statements — Annual L. Statements — Current Position M. ...