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T Rev B decision

Gordon Thomas Haig v. Minister of National Revenue, [1972] CTC 2562, 72 DTC 1465

The only manufacturer in those early days was Page-Hersey out of Welland, Ontario and that firm was supplying the whole of Canada at the same time as a German group called Canadian Phoenix, or Alberta Phoenix it is not clear just what the correct name at the material time was was considering setting up a pipe mill in Edmonton. ... At one point in the transcript counsel for the respondent inadvertently I hope used the phrase “reasonable expectation of profit”. ...
T Rev B decision

Domenic Cirella v. Minister of National Revenue, [1976] CTC 2292, 76 DTC 1211

(Sgd) M N Lacourcière J J Released: April 25th, 1972 398/69 IN THE SUPREME COURT OF ONTARIO BETWEEN: DOMENICO CIRELLA Plaintiff and GABRIEL KRUL, JOHN WILLIAM OWEN and VICTOR DROTAR Defendants LOSS OF INCOME Oct 18, 1968- Mar 10, 1969 20 weeks x $108.00 2,160.00 March 20, 1969- July 1, 1969 14 weeks x $108.00 1,512.00 July 12, 1969- August 12, 1970 13 months estimated 7,000.00 August 13, 1970- Dec 31, 1971 16 months and 2 weeks estimated 8,877.00 19,549.00 Less earned income for the year ended December 31, 1971 2,671.94 TOTAL LOSS OF INCOME $16,877.06 In commencement I should like to note the following: 1. ...
T Rev B decision

Tekarra Lodge LTD v. Minister of National Revenue, [1983] CTC 2369, 83 DTC 334

The sum of $285,000 was said to be “... for the licence of occupation granted by the Government of Canada.” ...
T Rev B decision

Raymond J Lemieux v. Minister of National Revenue, [1982] CTC 2018, 82 DTC 1039

Minister of National Revenue, [1982] CTC 2018, 82 DTC 1039 D E Taylor [TRANSLATION]:—This appeal was heard at Montreal, Quebec on November 17, 1980, and was brought from income tax assessments for 1977, in which the Minister of National Revenue refused the taxpayer the following deductions: Training course in Boston $1,097.35 Annual union, professional or other dues Association des médecins de langue française du Canada $ 5.00 Canadian Medical Protective Association 200.00 Association des médecins du Québec 30.00 235.00 $1,332.35 In making the assessment of the appellant, the respondent relied, inter alia, on section 3, paragraph 8(1)(i), subsections 8(2), 8(5), paragraphs 60(e) and 110(1)(g) of the Income Tax Act, SC 1970-71-72, c 63, as amended. ...
T Rev B decision

Roch a Choinière v. Minister of National Revenue, [1981] CTC 2305, 81 DTC 284

The statement of income and expenditures for these estates reads as follows: Fees $1,107.95 Knight (378-3939) 5,000.00 $6,107.95 Expenditures: Wages 441.91 Collection costs 1,421.00 Representation expenses 70.15 Automobile expenses 2,060.94 Travel expenses 177.20 Advertising and publicity 9.74 Rent 2,058.66 Telephone 515.24 Stamps and stationery 223.50 Office expenses 1,098.42 Books and magazines 459.08 Electricity 244.65 Legal and professional fees 1,554.00 Dues and membership fees 50.00 Interest and bank charges 2,056.69 Maintenance and repairs 204.70 Miscellaneous expenses 2,605.36 Moving 85.00 Bad debts 605.60 $15,941.84 Net loss before depreciation $ (9,833.89) ESTATE OF A LAROSE AND J CHOINIERE STATEMENT OF INCOME AND EXPENDITURES FOR THE YEAR ENDED OCTOBER 31, 1973 Income: Interest $11,876.26 Rent 8,459.00 $20,335.26 Expenditures: General upkeep of the houses 939.32 Electricity and heating 504.81 Plumbing 125.00 Tithes and repairs 156.53 Property and education taxes 4,729.52 Insurance 914.95 Legal and professional fees 1,800.00 Advertising and publicity 9.60 Collection costs 757.25 9,936.98 NET PROFIT (BEFORE DEPRECIATION) $10,398.28 The appellant therefore asked the Board to reduce the net profit to $6,205.10 ($10,398.28- $4,193.18) in view of the fact that he had paid this amount of $4,193.18 in interest. ...
T Rev B decision

John Balanko v. Minister of National Revenue, [1981] CTC 2977, 81 DTC 887

The appellant denied having any interest in the take or percentage or in any take or in any percentage of wagers which went to the house. ...
T Rev B decision

William N Brittain, Jr v. Minister of National Revenue, [1980] CTC 2707, 80 DTC 1617

On December 23, 1975, the appellant placed an order for the purchase of Government of Canada Bonds with a face value of $28,000, bearing interest at 9 /4 %. ...
T Rev B decision

F W Beyer v. Minister of National Revenue, [1978] CTC 2026, 78 DTC 1066

The former told him that they were interested—and I use his words, “... in less frivolous activities”. ...
T Rev B decision

Hubro Holdings LTD v. Minister of National Revenue, [1976] CTC 2078, 76 DTC 1068

On 13th June, 1973, the Respondent assessed the Appellant, by virtue of Section 184(1), on the ground the company had overstated at $2,064.15 the amount of its undistributed income on hand as a result of having failed to deduct in its computation incorporation costs of $67.00 and that Its undistributed income on hand at the end of 1971 amounted to $1,997.15. 4, The tax assessed on 13th June, 1973, in the sum of $56.95 was computed in the understated manner: Appellant’s Computation Minister’s Computation Appellant’s Undistributed Income On Hand $2,064.15 $2,064.15 Incorporation Expenses 67.00 1,997.15 15% Tax 309.62 299.57 Tax Paid Surplus 1,754.53 1,697.58 Dividend Paid 1,754.53 Amount By Which Dividend Exceeds $ 56.95 Tax Paid Undistributed Surplus The sum of $56.95 is $67.00 incorporation expenses less $10.05 being 15% thereof already paid as tax as a result of the overstatement. ...
T Rev B decision

Thomas Healy v. Minister of National Revenue, [1976] CTC 2098, 76 DTC 1087

For 1973 he worked as a money-room captain, accounting for moneys received from the sale of pari-mutuel tickets at three race tracks owned by the Jockey Club Woodbine, Greenwood and Fort Erie. ...

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