Search - 江西农大 毛瑢

Taxable Income Year Net Income Revised 1969 $8,585 $6,019.40 1970 $8,111 $5,541.80 1971 $3,215 $1,464.94 1972 $4,215 $ 834.86 3.4 Those amounts added were income from “profit on sub-division in Nova Scotia”. ...

Facts The appellant is a solicitor practising his profession with the firm of Gambin, Bratty, Chiappetta, Morassutti, Caruso, Barristers & Solicitors, Downsview, Ontario. ...

In his income tax returns for the taxation years 1965 to 1973, both inclusive, he reported the rent received as income. 3.6 The residence at 33 Hazelhurst Drive had an original capital cost to the appellant of $22,703.50. 3.7 The appellant, when filing his income tax returns for the taxation years 1965 to 1973, both inclusive, represented to the Minister of National Revenue that the said property was depreciable property and claimed capital cost allowance on the said dwelling as being a Class 6 asset as defined in the Income Tax Regulations. 3.8 The fair market value on December 31, 1971 of the residence at 33 Hazelhurst Drive was $38,500. 3.9 The fair market value of the same residence on January 1st, 1974 (when the appellant commenced to occupy personally the said residence) was $47,000. 3.10 The total capital gain is ($47,000 — $38,500) $8,500. 3.11 The amount of capital cost allowance claimed by the appellant between 1965 and 1974 both inclusive is $12,167.17. 3.12 By assessment on December 17, 1976, the respondent included in the computation of the appellant’s income the amount of $12,167.17 as recapture capital cost allowance and $4,250 as taxable capital gain. 3.13 Following a notice of objection dated March 7, 1977, to the assessment, the respondent confirmed the said assessment by a notification dated June 13, 1977. 3.14 An appeal dated September 8, 1977, was lodged before the Tax Review Board. 4. ...

. * If I interpret the said Exhibit correctly, and understood her. submissions properly, people employed in railway, mining or public service in India, mostly receive a once-in-a-lifetime bulk pension on the termination of their employment or retirement, and in these catagories the bulk payment would amount to approximately $500 in Canadian money. ...

Mr Roméo Rivet paid his ex-wife $45 a week, for a total of $2,340 in taxation year 1969 and $2,307 in taxation year 1970; 5. for the next three years, he paid his ex-wife $100 a week, for a total of $3,220 in taxation year 1971, $5,200 in taxation year 1972 and $5,200 in taxation year 1973; 6. these payments were made after an exchange of correspondence between Mr Roméo Rivet and his ex-wife; /. ...

Lots 1, 2, & 3 plus common use of Lot 4 (for parking), Block 37, Plan #22870 & #51315 in the town of Banff, Alta. ...

In a letter accompanying the reconciliation, Mr Aubin stated that the balance sheets submitted were based on the appellant’s original financial statements prepared for tax purposes from 1960 to 1970; on subsequent information obtained from the appellant himself; on documents which were seized by the Minister of National Revenue in the course of the search, and on the inventory of safety deposit box No 320 — the source of the list of investments at June 30, 1970, the securities on which were included in the capital reconciliation (Exhibit I-4). ... The submissions by counsel for the appellant that safety deposit box No 320 was rented for Mr Real Groleau’s will (Exhibit I-9) — which the appellant took occasion to point out was an authentic deed, by which Mr Groleau, and that Mr Real Groleau bequeathed to his sister Mrs Bousquet any contents of any safety deposit box which he might have in a bank or caisse populaire — in no way refute the two statements by the appellant, and in the circumstances of this appeal do not constitute evidence that the contents of safety deposit box No 320 belonged to Mr Réal Groleau. ...

During 1966/7 the subject company bid and obtained a contract for the North Sydney Harbour in which the following losses were incurred: April 30, 1968 (785,365) April 30, 1969 (210,429) April 30, 1970 (63,764) (1,059,558) On March 31, 1969, Canadian Dredge & Dock Limited (now Ablemont) took an option to acquire the shares in the Gorman companies. ... In his reasons stated at 48 and 126 respectively, Mr J O Weldon, QC, as quoted by the respondent said: In a non-technical sense the term “business” appears to embrace such matters as — name, owners or shareholders, management, employees, premises, machinery, stock-in-trade, product, goodwill and financial standing. ... The evidence is that, in the loss application years, only some of the assets in the appellant’s Maritime operations were sold; the appellant continued to seek-out and to bid on tenders for its marine construction operations in the Maritimes; a marine construction contract was awarded and carried out by the appellant in Newfoundland in the loss application years; marine construction contracts on which bids were made could have been executed in the Maritimes, either with the appellant’s marine equipment already located in Halifax or with equipment transported from the company’s Great Lakes & St Lawrence operations, or through the accepted practice of renting marine equipment from competitors. ...

March 23, 1971 42.47 $ 424,700 $10,000 2. July 4, 1972 97.08 $1,262,040 $13,000 3. ... July 27, 1973 50 $ 791,856 $15,837 3.12 Financing of each sales The financing of each sale is as follows: Sale Number 1 Financing: 106,566.66 due March 31, 1972 and 1973. ... However, the financing of property of Sale No 3 included an interest of 8% % per annum. ...

It was in fact agreed that these expenses would be compensated for through the commissions rather than being paid for directly by the City; as the appellant pointed out, it would have been difficult and “politically” embarrassing to claim these expenses, because it was difficult to calculate the exact expenditures for each occasion. 3.7 Both parties admitted that the following commissions were earned and expenses claimed for the year in question: Commissions Expenses 1973 $ 3,035.00 $3,500 1974 $10,595.04 $5,500 3.8 The evidence showed that 94 industrial prospects visited Granby in 1973, and 62 visited in 1974. 3.9 The details concerning these prospects were filed as Exhibit A-5 and A-6. ... According to the evidence, he spent approximately 70% of his working time at the office, if a working day is considered to be from 9 am to 5 pm. 3.15 Evidence was submitted that, as at September 1976, the industrial commissioner’s work since 1970 had brought the following results: —visits by industrial groups: 580; — new industries established: 89; —new investment: $65,705,087; —grants obtained for the investment: $22,365,00; —jobs created: 4,682. 3.16 The appellant filed a letter from the respondent relating to expenses authorized in 1970 as Exhibit A-4. ... According to the evidence submitted (paragraph 3.7 of the Facts), the commissions and expenses were: Commissions Expenses 1973 $ 3,035.70 $3,500 1974 $10,595.04 $5,500 No figures were given to show what proportion of the $3,500 and $5,500 claimed was for car expenses. ...