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FCTD

Her Majesty the Queen, Plaintiff,, [1977] CTC 423, [1977] DTC 5290

Invoices by the suppliers of most of these effects, Founders, show sales to Engelbrecht & Associates as purchasers and are dated July 16 and July 20, 1973. ...
FCTD

Burnac Corporation Limited, Burnac Realty Investors Limited, Burnac Mortgage Investors Limited and Joseph Burnett v. Minister of National Revenue, [1977] CTC 593, 77 DTC 5414

While I have been unable to find authority dealing with this exact point, the dicta in Granby Construction & Equipment Ltd v Milley, [1974] CTC 701; 74 DTC 6543, reversing [1974] CTC 562; 74 DTC 6300, a decision of the British Columbia Court of Appeal and of both the Chief Justice of Canada and the Chief Justice of Ontario in Canadian Bank of Commerce v Attorney General of Canada, 62 DTC 1236 (SCC), affirming [1962] CTC 39; 62 DTC 1014 (Ont CA) and [1962] CTC 35; 61 DTC 1264, as to the coersive nature of the power Parliament has given the respondent under section 231, formerly 126, of the Act, power which the Governor in Council may authorize others to exercise, remain pertinent. ...
FCTD

Peter D L Roper v. Minister of National Revenue, [1977] CTC 602, 77 DTC 5408

Both appeals will accordingly be dismissed with costs. 1 The proceedings in this Court were commenced before the coming into force of the Federal Court Act: this is why they were launched by way of "appeals” with the Minister of National Revenue being made a party thereto. 2 + Nevertheless, in these reasons, for convenience, I will refer to each individual taxpayer as the husband-appellant and the wife-respondent. ...
FCTD

Carl Caleb Cotton v. Her Majesty the Queen, [1976] CTC 406, 76 DTC 6232

The opening words of paragraph 4 “The husband shall pay to the wife, in addition to the sum set out in paragraph 3 above.. ”, indicate that this is so. ...
FCTD

Arthur R Ammerman* v. Her Majesty the Queen, [1976] CTC 616, 76 DTC 6356

His only intention was to build a home and live on it, an intention frustrated by the “freeze” imposed as a result of the annexation and not yet lifted when the land was finally sold. 2 *} should record that neither Wallace nor Norma Ammerman were called to testify. ...
FCTD

John McAdam v. Minister of National Revenue, [1973] CTC 215, 73 DTC 5189

The defendant also relied on paragraph (a) of subsection (4) of section 83 which provides that the exempting provisions do not apply “... in the case of a person who disposes of the shares while or after carrying on a campaign to sell shares of the corporation to the public,...’. ...
FCTD

Harold J C Terry v. Minister of National Revenue, [1973] CTC 349, 73 DTC 5291

Both Sannie and Skeena were successful in arranging for the use of the entire proceeds of disposition of each of the vessels as provided under the terms of the CVCA Act but in so doing necessarily incurred the following costs: Sannie $108,318.30 Skeena $ 63,033.56 In its reply (paragraph 5) the respondent alleges: 5. ...
FCTD

Numisia Boccia and Armand Boccia v. Her Majesty the Queen, [1973] CTC 731, 73 DTC 5522

The subsequent survey resulted in an adjustment of the purchase price to $368,700, the first mortgage was $36,400 and the vendors accepted a second mortgage of $252,310 at 7 / for a term of ten years. ...
FCTD

Le Soleil Limitee v. Minister of National Revenue, [1972] CTC 244

First, I feel that manufacturing and processing are both involved in producing a newspaper, but that even if processing were not involved manufacturing would suffice, since subsection 40A(2) uses the disjunctive wording “... of goods processed or manufactured in Canada”. ...
FCTD

Ernest C. Hammond v. Minister of National Revenue, [1971] CTC 663, 71 DTC 5389

The appellant asserted, and there is no reason not to believe him, that during all those years he was in a good financial situation and was not relying on horses to make money It is against this background that the appellant’s horse racing activities must now be seen. ...

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