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T Rev B decision

Donald B Macdonald v. Minister of National Revenue, [1974] CTC 2204, 74 DTC 1161

I quote the section because it is short: 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: (ia) an amount paid by the taxpayer in the year as or on account of expenses incurred by him in attending, in connection with a business or profession carried on by him, not more than two conventions held during the year by a business or professional organization; There is no doubt that the conventions in question were held by business or professional organizations, nor is there any doubt—in fact, it is admitted—that the degree of success and study that Mr MacDonald has put into his vocation would qualify him as a professional within the meaning in my decision in Axler & Palmer Ltd v MNR, [1973] CTC 2167; 73 DTC 119. ...
T Rev B decision

Stubart Investments Limited v. Minister of National Revenue, [1974] CTC 2284

The term “sham” has become quite common in income tax law and I quote, as the learned counsel for the Crown did, from the decision of Lord Justice Diplock in Snook v London & West Riding Investments Ltd, [1967] 1 All ER 518 at 528. ...
T Rev B decision

Estate of Hyman Kamichik v. Minister of National Revenue, [1973] CTC 2208

Again, it is agreed: that the deceased’s wife and one or more of his children survive him and are alive at all material times (The executors named under the Will are the testator’s wife, his brother-in-law and his accountant);— that “the said Will instructs the executors and trustees to hold the residue of the estate in trust and to pay one half of the net revenue thereof to the deceased’s wife for life, the other half to be accumulated until such time as the deceased’s children reach the age of 25, at which time the accumulated revenue is to be distributed to these children and thereafter one-half of the net revenue shall be paid directly to them in equal shares”; and that upon the death of the wife of the testator, the capital of the estate is to be divided equally amongst the children, with the usual clauses pertaining thereto. ...
T Rev B decision

Red Barn System (Canada) Limited v. Minister of National Revenue, [1973] CTC 2290, 74 DTC 1021

What in fact happened was that, in Western Canada, Mr Swift, through his companies, was obliged to buy or to take a minimum equity of 10% in the operating company and in fact took considerably more through his own company and through his brother. ...
T Rev B decision

Morris Besney v. Minister of National Revenue, [1972] CTC 2052, 72 DTC 1078

During the construction the partnership (Dr Besney, Mr Sorokin and Milton) encountered all kinds of difficulties to name a few: the reduction of the first mortgage from $1 million to $900,000; the collapse of Atlantic Acceptance Corporation; the rental losses suffered by virtue of vacant apartments; and the fact that the building was not finished until about four months after the scheduled completion date. ...
T Rev B decision

William J Hilton v. Minister of National Revenue, [1972] CTC 2067, 72 DTC 1073

The Concise Oxford Dictionary defines the word “throughout” as follows: Adv & Prep 1. ...
T Rev B decision

Avon Realties and Investments Corp v. Minister of National Revenue, [1972] CTC 2114, 72 DTC 1093

WHEREAS the Vendor alleges that on January 28, 1964, June 28, 1964, and October 28, 1964, he was the registered owner of all that certain parcel or tract of land being composed of lot 50-361, 362, 363, 364 & 365 of the Official Cadastre of the Parish of Montréal and whereas on the said days of January 29, 1964, June 29, 1964, and October 29, 1964, the said parcel or tract of land was taken by the Government of the Province of Quebec, represented by the Minister of Roads, according to the dispositions of article 1066V of the Code of Civil Procedure as per a notice of expropriation filed on January 29, 1964, June 29, 1964, and October 29, 1964, with the Registrar of Deed for the County of Montréal under numbers 1,724,679, 1,759,352 and 1,786,309. ...
T Rev B decision

James Foster Irwin v. Minister of National Revenue, [1972] CTC 2239, 72 DTC 1201

Each of the six operation reports states that the customer is J Foster Irwin and identifies the purpose of the flight in question as the “McDonald & Vincent Job”. ...
T Rev B decision

James F McDonald v. Minister of National Revenue, [1972] CTC 2243, 72 DTC 1204

Each of the six operation reports states that the customer is J Foster Irwin and identifies the purpose of the flight in question as the “McDonald & Vincent Job”. ...
T Rev B decision

John P Vincent v. Minister of National Revenue, [1972] CTC 2246, 72 DTC 1206

Each of the six operation reports states that the customer is J Foster Irwin and identifies the purpose of the flight in question as the “McDonald & Vincent Job”. ...

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