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EC decision
Hilliard C. McConkey v. Minister of National Revenue, [1935-37] CTC 341
And in the second column you have items under " Taxable income ‘; what are those figures? ... The effect was that when he became liquidator there was that much less available for distribution to the shareholders because they had already received that. ‘ ‘ Q. ... In this case the capital recovery would amount to $143,369.21, as follows: Amount distributed in 1930_. $ 17,946.64 " " ‘ ‘ 1931 18,000.00 "" ‘ ‘ " 1932 12,000.00 Amounts distributed by the liquidator ($75,000 and $1,500) 76,500.00 Accounts receivable and money assigned to Royal Trust Co. 18,922.57 $143,369.21 If we deduct the amount assigned to the Royal Trust Co., namely, $18,922.57, for accounts receivable and cash on hand, we are left with a balance of $124,446.64. ...
EC decision
William Harold Malkin v. Minister of National Revenue, [1938-39] CTC 128
(hereafter referred to as " the Malkin Company”) which carries on the business of wholesale grocers in the same city. ... If justification to tax the appellant is sought in the word " " emoluments ‘ ‘ in the general definition of ‘ ‘ income, ‘ ‘ it cannot be said that such " " emolument, ‘ ‘ namely, the occupation of Southlands, is one "‘directly or indirectly received by any person from any office or employment, or from any profession or calling, or from any trade, manufacture or business.’’ ...
EC decision
Minister of National Revenue v. J.-Emile Groulx, [1966] CTC 115, 66 DTC 5126
Le procureur de l’appelant se dit alors désireux de fournir des chiffres plus exacts et produisit l’exhibit A-2, qui se lit comme suit: 2,226,359 pieds carrés à 12^^ $278,294.87 2,226,359 ‘' 6 “ 15 $333,953.85 2,226,359 “ ‘6. “20^ $445,271.80 Le procureur de l’intimé continue: “Q. ... Pour établir une valeur moyenne nous avons additionné le prix par pied carré de toutes les ventes en excluant celles en bas de $0.09 cents du pied carré, que nous croyons ne représentent pas la valeur réelle du terrain au pied carré à cette époque, nous obtenons une moyenne de $0.1114 cents du pied carré, voir détails ci-après:— Vente No. 2 $0.12 “ ‘ ‘ 3 0.12 ‘ ‘ ‘ ‘ 5 0.126 cc ‘ ‘ 10 0.1085 “ ‘ ‘ 1.3 0.108 ‘ ‘ ‘ ‘ 14 0.125 ‘ ‘ ‘ ‘ 16 0.123 ‘ ‘ “ 17 0.0948 Total: $0.925 ~ 8 $0.115 p.c. ... I think we arrived to a price close to $400,000 ‘to be paid ¢ o a period of 6 or 8 years’, I don’t remember again. ...
EC decision
Harry Moluch v. Minister of National Revenue, [1966] CTC 712
The appellant sold the following number of lots in the years indicated: 1955 — 5 lots 1959 —11 lots 1956 — 23 “* 1960 — 12 °° 1957 — 18 “ 1961 — 10 “* 1958 — 10 “ 1962— 7 “ In his testimony the appellant frankly stated that it was his hope and intention to sell every lot in the subdivisions excepting his own home. ... C.R. 40; [1951] C.T.C. 322, Thorson, P. said, “... the Court must be careful before it decides that a series of profits, each one of which would by itself have been a capital gain, has become profit or gain from a business. ... It follows that the appeal is dismissed with costs. 1 * 3, The income of a taxpayer for a taxation year for the pur poses of this Part is his income for the year from all sources in side or outside Canada and, without restricting the generality of the foregoing, includes income for the year from all (a) businesses, (b) property, and (c) offices and employments. 4. ...
EC decision
Weinberger v. MNR, 64 DTC 5060, [1964] CTC 103 (Ex Ct)
Basically the Minister’s case is that the appellant is not entitled to the capital cost allowance claimed because the patent cost the appellant nothing but the legal expenses of obtaining it and in support of this position he challenged the evidence that the expenses in question were incurred and submitted that even if they or some portion of them were incurred they did not constitute any part of the ‘ ‘ cost ’ ’ or the ‘ ‘ capital cost ’ ’ or the ‘ actual capital cost’’ of the patent within the meaning of these expressions as used in the Income Tax Act and the Regulations made pursuant thereto. ... By Section 12(1)(b) of the Income Tax Act, R.S.C. 1952, c. 148, it is provided that in computing income, no deduction shall be made in respect of an outlay, loss or replacement of capital, a payment on account of capital or an allowance in respect of depreciation, obsolescence or depletion except as expressly permitted by Part I of the Act but by Section 11(1) (a) it is also provided that: “11. (1) Notwithstanding paragraphs (a), (b) and (h) of subsection (1) of section 12, the following amounts may be deducted in computing the income of a taxpayer for a taxation year: (a) such part of the capital cost to the taxpayer of property, or such amount in respect of the capital cost to the taxpayer of property, if any, as is allowed by regulation;” Section 1100(1) (c) of the Income Tax Regulations as applicable to the year 1954 provided that: “1100. (1) Under paragraph (a) of subsection (1) of section 11 of the Act, there is hereby allowed to a taxpayer, in computing his income from a business or property, as the case may be, deductions for each taxation year equal to (c) such amount as he may claim in respect of a property of class 14 in Schedule B not exceeding the lesser of (i) the amount for the year obtained by apportioning the capital cost to him of the property equally over the life of the property remaining at the time the cost was incurred, or (ii) the undepreciated capital cost to him as of the end of the taxation year (before making any deduction under this subsection for the taxation year) of property of the class;’’ Schedule B, Class 14 reads in part as follows: ‘ ‘ Schedule B CLASS 14 Property that is a patent, franchise, concession or licence for a limited period in respect of property...” ... That subsection provides that in the case of property held at the commencement of the 1949 taxation year, for the purposes of regulations made under Section 11(1) (a) of the Act, the property (in this case the patent) ‘‘ shall be deemed to have been acquired at the commencement of the year at a capital cost equal to the actual capital cost’’ less the amount therein mentioned. ...
EC decision
Parsons-Steiners Limited v. Minister of National Revenue, [1962] CTC 231
During 1953 correspondence passed between the appellant and Doulton & Co. ... Basil Green of Doulton & Co. Limited which simply said: “Dear Mr. ... Inland Revenue into that of Barr, Crombie & Co. v. Inland Revenue. ...
EC decision
Minister of National Revenue v. Dr. Jean Beaudin, [1964] CTC 70, 64 DTC 5077
Le Ministre du Revenu national ajoutait aux profits déclarés par l’intimé pour les années 1957, 1958 et 1959, les montants ci-dessous: 1957 — $ 4,230 1958 — $ 6,918 1959 — $20,000 Ces ajoutés aux déclarations du Dr. ... It is extremely difficult to express, but it seems to me that people would say he is addicted to betting, and could not say that his vocation is betting. ’ ’ BETTING ON PERSONAL SKILL. ... Green. ’ ’ ’ PAR TOUS CES MOTIFS, la Cour confirme la décision de la Commission de l’impôt et rejette l’appel, avec allocation des dépens de Cour à l’intimé, après taxation. ...
EC decision
Isadore Weinstein v. Minister of National Revenue, [1968] CTC 357, 68 DTC 5232
Add: Reserve deducted under Section 85B in computing your 1961 income 15,000 The amounts of tax actually assessed against the appellant in the taxation years 1959, 1960, 1961 and 1962 are identical with the amounts that would have been assessed if the respondent had in fact assessed the appellant on the basis that the appellant had adopted pursuant to Section 85B of the Income Tax Act a cash basis for computing this profit from this ‘ ‘ business ’ ’. ... The determination of this issue is dependent (i) on the true interpretation of the provisions of Section 85B(l)(b) of the Income Tax Act in relation to the question of whether the respondent may set up and employ a reserve under Section 85B(1)(d), that is, assess the appellant on the basis that the appellant adopted an accrual basis for computing profit from this business ’’ when the appellant had taken no position either in any written document delivered to the respondent or verbally as to how he wished to compute the profit from this “business”, that is, neither the position that he wished it computed by the cash method nor by the accrual method; and (ii) whether on the facts of this case this reserve of $30,000 was again deducted in 1960 by the appellant pursuant to Section 85B(1) (d) of the Income Tax Act in computing his income for the taxation year so as to avoid including it in his 1960 income pursuant to Section 85B(1)(e) of the Act. ...
EC decision
Lions Gate Lumber Company Limited v. The Minister of National Revenue, [1951] CTC 279, [1951] DTC 550
It defines " " capital employed in any year or fiscal period, ‘ ‘ while Section 15A is concerned with capital employed ‘ ‘ at the time of incorporation’’ and "‘prior to incorporation’’. ...
EC decision
His Majesty the King v. Boultbee Limited., [1938-39] CTC 78
See. 86(1) is in part as follows: * • There shall be imposed, levied and collected a consumption or sales tax of eight per cent on the sale price of all goods (a) produced or manufactured in Canada, payable by the producer or manufacturer at the time of the delivery of such goods to the purchaser thereof.’’ ... There is no particular significance in the word "‘retreading’’ and one can only say it is a very convenient and descriptive term to use, Just as the word ‘ " sole ‘ ‘ is used in respect of shoes. ... I cannot think that the words " ‘ manufacture, ‘ ‘ or ""goods,” mentioned in 87(c) include, or were intended to include, transactions of the nature which I am discussing, or that such transactions were intended to be treated as sales. ...