Search - 江西农大 毛瑢

As a result of an agreement made by counsel during the course of the trial the parties have informed the Court that reasonable amounts for the two taxation years under appeal are as follows: 1959 — Horizon and Blue Chip Reserve: $139,602.32 Save-a-Tape Reserve: 25,570.28 Total — $165,172.60 1960 — Horizon Stamp Reserve: $509,987.64 The appellant’s principal contention is, in effect, that the manner in which the appellant conducted its business, which has been described above, falls within the precise terms of Section 85B in that part of the purchase price received by the appellant in the course of each of its sales at a store where such a plan was in operation, was received on account of goods not delivered before the end of the year. ...

Shulman caused Shultup Management & Investments Ltd. to be incorporated. ... THE COMMON SEAL of SHULTUP SIGNED, SEALED and DELIVERED MANAGEMENT & INVESTMENTS by SHULMAN, TUPPER, SOUTHIN, LTD. was affixed hereto in the GRAY & WORRALL, per: presence of: in the presence of: (No signature) (Signature illegible) (Sed.) ... L.); Pioneer Laundry & Dry Cleaners Ltd. v. M.N.R., [1940] A.C. 127 (P.C.); [1938-39] C.T.C. 411; Duke of Westminster v. ...

Taxable Income Tax 1964... 10,000 $ 29,745.93 $10,864.26 1965 32,400 $109,367.58 $57,398.98 The questions that arise on this appeal fall into two groups. ... Once the actual licensed staker has so acquired such rights, usually referred to as ‘ claims ’, he may sell or otherwise dispose of them to someone else. ... In my view, that was an arrangement between the syndicate and Geophysical Engineering & Surveys Limited, the staking company. ...

Crispo & Company’’. In the main, the business consisted of importing goods from the United States and selling them in Canada. ... It is clear, notwithstanding much talk about consultations with the widow, suggestions by her, etc., that the real reason why, in 1958, Archer wanted an arrangement under which, upon the deceased’s death, the widow would become associated with the company in some capacity, was that he thought that the “ Crispo” relationship with the New York and Chicago people would have an advantage to the Company. ... What paragraph (1) (ii) of Section 3(1) contemplates is that property disposed of under the terms of an agreement that was made by the deceased for valuable consideration given by the deceased and that provided for that disposition should be included in the ‘ aggregate net value ’ In other words, where the deceased paid for property in his lifetime, it should be included in his estate for tax purposes even though it was delivered directly to a beneficiary on or after his death. ...

The witness acknowledged that he had done title work for Central Mortgage & Housing Corporation, but declared that this had only occurred after the Company had sold the remaining 95 acres of the instant property to Central Mortgage & Housing Corporation, as already indicated. ... ANDERSON ALAN DIGNAN — to the extent of % interest each P. J. WALSH J. ... Spencer, [1961] C.T.C. 109 at 132, I think, are applicable in the present case: ‘,... ...

In other words it is an attempt to cover what, in the vernacular of the business, is referred to as a “ grubstaking ” arrangement. ...

The computation of 1955 taxable income of the company as determined by the re-assessment is: Taxable income declared by company $ 789.76 Capital cost allowance claimed by com pany $4,570.17 Capital cost allowance as determined by the Minister 104.67 Add to income as declared 4,465.49 Taxable income as revised and as assessed $5,255.25 Benjamin Richard Steen, the president of the company, testified respecting the 1946 acquisition of the property. ... At the time of the sale the rentals being derived from the buildings were: Zenith Electric Supply — $2,000.00 per month Herbert A. Watts Limited 855.00 u “ Stephen Sales Limited 541.66 u *: Trevelyan Manufacturing Co. 225.00 ‘:‘ L $3,621.66 The annual gross income approximated $44,000.00 and the annual net income, before administration expense, was in the vicinity of $22,000. ...

Stuart and $. E. Nicholson, who together held 2,177 shares, for some time did control it and dictate its policies. ... Allowed or Claimed Deducted (3)- 5% Class 2,603.11 2,834.93 Class (8) — 20% 17,435.09 9,681.44 Class (10) — 30% 99.48 210.40 Class (11) — 50% 1,031.36 1,770.13 21,169.04 14,496.90 Net Disallowances 6,672.14 $21,169.04 $21,169.04 By his Notice of Assessment dated January 18, 1951, the appellant assessed the taxable income of the respondent new company at $62,510.16, increasing to that amount its declared income of $47,585.31 as follows: Adjustments of Income Declared Net Income Declared 47,089.31 Capital Cost Disallowance re Section 20 (2) 6,672.14 Bond Interest Disallowance re Section 11 (l)(c) and Section 12 (l)(c) 6,678.10 Bank Interest Disallowance re Section 11 (1)(c) 1,574.61 $62,510.16 The income tax levied was $19,412.19, to which was added interest amounting to $144:52, making the total amount payable $19,556.71, against which was credited the amount remitted by the respondent new company with its income tax return of $15,552.46, leaving a balance due of $4,004.25. ... And at page 147 [C.T.C. at page 81]: “... the appellant has been proved and indeed admitted not to be controlled by the Enzlish company. v ”’ On appeal to the Privy Council, M.N.R. v. ...

Sale to Murray $ 600.00 Item B. Sale to O’Hanian 1,400.00 Item C. Sale to Robinson.,. 4,146.00 Item D. ... Martin & Martin, to deduct from the purchase price paid by Cochren Construction Co. ... ” And in explanation of Nelmar’s purchase of ‘‘ Edgecliff’’, Wright said: “Yes I have nothing to lose. ...

Such is the outline of this case which squarely raises the issue of what, in the eyes of the law, constitutes a ‘ personal corporation”, and, accessorily, the rational meaning attaching to financial business ‘‘actively carried on’’. ... Finning Tractor and Equipment Limited supplies it with its iness. ’ In this analysis I thoroughly concur. ... Assuredly, the situation just revealed is of the class which the legislator envisaged when he wrote into the law subsection (¢) of Section 68(1): “ (c) did not carry on an active financial, commercial or industrial business.’ ...