Search - 江西农大 毛瑢

From the Shorter Oxford English Dictionary Volume 11 the word tillage is defined as follows: Tillage — 1488 (f Till v 1 +-Age). 1. ... For that proposition counsel relied on a decision of the Judicial Committee of the Privy Council in Rex v British Columbia Fir & Cedar Lumber Company, Limited, [1932] 2 WWR 153. ...

The mechanism chosen by the appellant in this appeal, and in most such appeals, is to present evidence in support of a different valuation — in this case $6,000 per acre. ... Counsel for the appellant asserted the unique situation of the property — located in such a place it appeared relative to main highways and potential growth, and indications of a substantial shopping plaza development on or near the site. ...

A corporation known as Ricenburg Developments Limited held 50% of the shares; Messrs Meister and Beallor held 12 /2 %; and a corporation known as Belle Gardens Properties Limited also held 12%%. ... At pages 376 and 5226 respectively, Mr Justice Judson said: “... this was merely an alternative method that they chose to adopt in putting through their real estate transactions. ...

In filing his income tax returns for the 1975 and 1976 taxation years, the appellant reported the following real estate transactions: Date of Date of Gain Gain Address Purchase Sale Sale Reported 1457 Edgar St Jan/74 Aug/75 $ 1,563.40 2134 Lome St June/74 Sept/75 5,695.26 2021 Embury St Nov/75 Jan/75 1,925.60 1012 Rae St July/75 Oct/76 19,300.00 1340 Broder St May/76 Dec/76 464.50 The appellant declared the profits made on the sale of those properties as capital gain but he was reassessed as gains on income by the respondent. ... MNR v Edgeley Farms Limited, [1969] CTC 313; 69 DTC 5228; Coronation Holdings Limited v MNR, [1968] Tax ABC 513; 68 DTC 419, and Rokosh Engineering & Construction Ltd v Her Majesty the Queen, [1974] CTC 536; 74 DTC 6375. ...

Counsel for the Minister cited the following jurisprudence: Savary Beach Lands Ltd. et al v MNR, [1972] CTC 2608; 72 DTC 1497; '; Antonio Arnone v MNR, 79 DTC 22; James Wayne Elliott v MNR, [1978] CTC 2919; 78 DTC 1643; Tic Toe Tours Ltd. v MNR, [1981] CTC 2776; 81 DTC 660; Robert Newton et le Ministre du revenu national (APP-2590). ... I appreciate that the use of the word “may” on the reverse side of the assessment notice accurately reflects that the same word is used in the construction of the relevant section of the Income Tax Act — subsection 165(1) thereof. ...

. — There was no intention of purchasing or retaining the said property for any other purpose than a Chrysler dealership. ... Reference was made to S & S Properties Ltd v MNR, [1977] CTC 2267; 77 DTC 190, and Ronald Francis Theres Maclsaac v MNR, [1974] CTC 576; 74 DTC 6380. ...

During those years the appellant was employed as a union representative by the British Columbia Council of the Retail Wholesale & Department Store Union. ... The position of the respondent was that each of the amounts in question “... was an allowance within the meaning of paragraph 6(1)(b) and were not an exception within the meaning of subparagraph 6(1)(b)(v) or clause (vii)(a)”. ...

RENTAL INCOME $ 3,600 EXPENSES Mortgage interest $4,587 Condominium expenses 3,765 Repairs and maintenance 1,843 Interest and bank charges 1,904 Realty taxes 1,117 Closing costs 728 Utilities 925 Travel and set-up costs 757 Telephone 483 Management fees 300 Accounting 300 Depreciation—Furniture and fixtures 2,283 18,992 NET LOSS $15,392 SILVERTHATCH INVESTORS STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 1975 RENTAL INCOME $ 2,769 EXPENSES Mortgage interest $5,435 Condominium expenses 3,157 Repairs and maintenance 242 Interest and bank charges 290 Realty taxes 1,297 Tennis membership and costs 571 Utilities 657 Telephone 418 Management fees 300 Audit fees 300 Legal fees 1,804 14,471 NET LOSS $11,702 The appellant attributed the difficulties in the first year in achieving what he said were the anticipated revenue levels to delays on the part of the painters in completing the apartment. ...

Background The taxpayer inherited a substantial portfolio of investments and incurred the following expenses servicing these investments: Investment Services—$943.24 Telephone Charges— 503.71 $1,446.95 Contentions The position of the appellant was as follows: — In order to maintain her investment portfolio in good standing for the purpose of ensuring a proper return of income the taxpayer subscribed for various investment services, and kept in continual contact with various brokers by a business telephone specifically used for that purpose. ... I have been unable to discern in the more recent jurisprudence the perspective put forward by counsel and, by way of contrast and clarification, I would make reference to the case of Her Majesty The Queen, v Baine, Johnston & Company Limited, [1977] CTC 556; 77 DTC 5394. ...

Subsection 125(1) reads as follows: 125. (1) Small business deduction—There may be deducted from the tax otherwise payable under this Part for a taxation year by a corporation that was, throughout the year, a Canadian-controlled private corporation, an amount equal to 25% of the least of (a) the amount, if any, by which (i) the aggregate of all amounts each of which is the income of the corporation for the year from an active business carried on in Canda, exceeds (ii) the aggregate of all amounts each of which is a loss of the corporation for the year from an active business carried on in Canada, (b) the amount, if any, by which the corporation’s taxable income for the year exceeds the aggregate of (i) 10/4 of the aggregate of amounts deducted under subsection 126(1) from the tax for the year otherwise payable by it under this Part, and (ii) 2 times the aggregate of amounts deducted under subsection 126(2) from the tax for the year otherwise payable by it under this Part, (c) the corporation’s business limit for the year, and (d) the amount, if any, by which the corporation’s total business limit for the year exceeds its cumulative deduction account at the end of the immediately preceding taxation year, except that in applying this section for a taxation year after the 1972 taxation year, the reference in this subsection to “25%” shall be read as a reference to “24% for the 1973 taxation year, “23% for the 1974 taxation year, “22%” for the 1975 taxation year, and “21 %” for the 1976 and subsequent taxation years. ... Mr Rosborough originally resided in Winnipeg, Manitoba and was with Rosborough, Southam &. ...