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SCC

Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 SCR 496

Cohen and $. J. Cohen were brothers and Leshgold their brother-in-law and that J. ... In support of this contention, the cases on the construction of the words 4 relatives or relations in matters involving the interpretation of wills such as Ross v. ... :—There are here two appeals, one by Army & Navy Department Store Limited, an Alberta company (hereinafter referred to as the Alberta Corporation) and the Army & Navy Dept. ...
T Rev B decision

Simon, Voyer & Castelli Inc v. Minister of National Revenue, [1979] CTC 2503, 79 DTC 41

L’appelante en effet a acquis de nouveaux clients importants dont la nature et le montant des primes sont tels que ci-après décrits: Noms de nouveaux clients Primes Une compagnie de construction $ 52,000 Une compagnie de matériaux de construction $ 35,000 Une compagnie de bois $ 88,000 Une compagnie d’acier $ 70,000 Un commerce de moulin à scie $ 14,000 $259,000 Le revenu additionnel qui en est découlé constitue environ $40,000 à $45,000 de commissions. 3.13 Un autre élément d’augmentation de revenus, selon M Castelli, fut l’augmentation des primes d’assurance-automobile. ... Sa Majesté la Reine c Baine, Johnston & Co Ltd, [1977] CTC 556; 77 DTC 5394; 8. Crosbie & Co Ltd c MNR, [1978] CTC 2091; 78 DTC 1083; 9. Walter J Burian c Sa Majesté la Reine, [1976] CTC 725; 76 DTC 6444; 10. ...
T Rev B decision

Kocisko-Senecal & Associates LTD and Joseph Kocisko v. Minister of National Revenue, [1981] CTC 2613, 81 DTC 481

Rosenhek & Machlovitch, Suite 1700 One Westmount Square, in the City of Westmount, Province of Quebec, on March 17th, 1977, or on such earlier or later date as may be agreed upon by the Purchaser and the Vendor. ... Findings The position of counsel for Mr Senecal is a rational one that Senecal simply would not have accepted $50 for stock worth some $28,850 and counsel made a convincing case for the acceptance of his position. ... Whatever else may arise from an examination of this matter, his claim to a capital gain is unfounded the $26,450 at issue was not for the sale of his stock it is salary income to Senecal in the year 1977. ...
FCTD

Canadian Propane Gas & Oil Ltd. v. MNR, 73 DTC 5019, [1972] CTC 566 (FCTD)

Canadian Propane Gas & Oil Ltd. v. MNR, 73 DTC 5019, [1972] CTC 566 (FCTD) Cattanach, J:—These are appeals from the assessment of the appellant to income tax for its 1966 and 1967 taxation years by the Minister. ... Subsequently the corporate name was changed to Canadian Propane Gas & Oil Limited. ... In assessing the appellant as he did the Minister invoked the provisions of paragraph 20(6)(g) of the Income Tax Act and accordingly reduced the capital cost of the Class 8 and Class 10 depreciable assets as follows: Class 8 Class 10 Total Zenith Purchase price $161,000.00 $136,000.00 $297,000.00 Allowed by Minister 55,685.00 53,742.00 109,427.00 Reduction $105,315.00 $ 82,258.00 $187,573.00 Burro Purchase price $242,685.00 $246,150.00 $488,835.00 Allowed by Minister 65,726.00 78,337.00 144,063.00 Reduction $176,959.00 $167,813.00 $344,772.00 Grover’s Purchase price $145,530.00 $ 41,532.00 $187,062.00 Allowed by Minister 62,750.00 30,532.00 93,282.00 Reduction $ 82,780.00 $ 11,000.00 $ 93,780.00 In determining the amounts that the Minister allowed as being reasonably regarded as being in part the consideration for the depreciable property within Classes 8 and 10, the Minister considered each item within those classes as outlined in Schedules A, B and C to his Reply to the Notice of Appeal. ...
NSPC decision

R. v. Spryfield Bingo & Amusement Centre Ltd., [1998] 1 CTC 158

A set of 9000 series comes as follows: a) I on = 9000 sheets b) 2 on = 4500 sheets c) 3 on = 3000 sheets d) 6 on = 1500 sheets The 6000 series means 6000 individual cards or faces. The 6000 series comes as follows: a) 7 on = 6000 sheets b) 2 on = 3000 sheets c) 3 on = 2000 sheets d) 6 on = 1000 sheets All bingo supplies were ordered from C.I.C.. ... The Crown based upon the assumptions as outline in paragraphs 58 and 59 above if correct would have unreported income against Spryfield Bingo in the following amounts: UNREPORTED INCOME TAX EVADED 1984 $ 345,321.00 $ 89,602.52 1985 $ 464,458.00 $167,428.24 1986 $ 513,809.00 $190,555.07 1987 $ 359,935.00 $135,117.21 $1,683,523.00 $582,703.04 61. ...
T Rev B decision

Lambert & Grenier Inc v. Minister of National Revenue, [1979] CTC 2929, 79 DTC 486

Veuve Clément Bouchard & Euclide Bouchard es qualité v Diane Lepire, [1974] CA 616; 17. ... Union Insurance Society of Canton Limited & André Arsenault, [1961] S.C.R. 766; 22. ... Eugène Lagacé <& George Lagacé v MNR, [1968] CTC 98; 68 DIC 5143; 41. ...
EC decision

MNR v. Panther Oil & Grease Manufacturing Co. of Canada Ltd., 61 DTC 1222, [1961] CTC 363 (Ex Ct)

The Shorter Oxford English Dictionary gives the following meanings for the word agency ’: “1. ... Established or stable conditions —1777; organization, footing 1799. 3. ... That which is established; a settled constitution or government 1793. 2. ...
TCC

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280

Dow & Duggan Log Homes International (1993) Limited v. The Queen, 2019 TCC 280 Docket: 2017-2928(GST)G BETWEEN: DOW & DUGGAN LOG HOMES INTERNATIONAL (1993) LIMITED, and HER MAJESTY THE QUEEN, Respondent.   ... Factual background Deposits and work-in-progress [59]   With respect to work-in-progress, Mr. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
EC decision

Her Majesty the Queen v. W. D. Armstrong & Co. Ltd., [1970] CTC 175, 70 DTC 6148

The Delta Glucose case was interpreting the words consumable materials as they appeared in Schedule III to the Act at that time, but the words used in Schedule III in the period under consideration in the present case are ‘‘consumed or expended’’ which I consider to be broad enough to include the matrices which are discarded after one use. ... The fact that the matrices are subsequently ‘‘ consui^d or expended in the process of manufacture” of the rubber stamps as I have found does not alter the fact that before they are so consumed or expended they constitute ‘‘articles’’ rather than ‘‘materials’’. ... Armstrong & Co. Ltd. v. Deputy Minister of National Reve nue for Customs and Excise, [1967] 1 EX.C.R. 346; [1966] C.T.C. 778. 3 +R.S.C. 1927, c. 179. 4 * Judgment October 7, 1969. (1969), 23 D.T.C. 5372; [1969] C.T.C. 574. 5 *Canadian Sales Tax Reports 8561. 6 *Tariff Board Reports 1963-1966, p. 192. 7 ^Tariff Board Reports 1937-1956, p. 7. 8 tTariff Board Reports 1957-1962, p. 215. ...
TCC

A & D Precision Limited v. The Queen, 2019 TCC 48

A & D Precision Limited v. The Queen, 2019 TCC 48 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Russell” Russell J.   Citation: 2019TCC48 Date: 20190228 Docket: 2014-3465(IT)G BETWEEN: A & D PRECISION LIMITED, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Introduction: [1]   This is a scientific research & experimental development (SR&ED) case. ...

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