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FCA

The Queen v. Canadian General Electric Co. Ltd., 87 DTC 5070, [1987] 1 CTC 180 (FCA)

Richardson is writing to you reporting about HEPC that’s Ontario Hydro, my Lord, HEPC that’s what HEPC stands for. ... At this time we are now looking at the date of this letter which is June 27, 1968. ... He approached me well at that time, 1968, we were still a couple of years from completion. ...
FCA

Stephens v. The Queen, 87 DTC 5024, [1987] 1 CTC 88 (FCA)

Stephens notices of reassessment having, on the left-hand corner, the words “Revenue Canada Taxation” (instead of Department of National Revenue Taxation) and, at the bottom, the printed signature of a former Deputy Minister followed by the words “Deputy Minister of National Revenue for Taxation”? ...
FCA

Netupsky v. R., [1996] 2 CTC 29, 96 DTC 6129

.: We are all of the view that this appeal cannot succeed. We think that the learned Tax Court judge dealt properly with the issues raised and we substantially agree with her reasons. ...
FCA

Canadian Union of Public Employees v. Minister of National Revenue, [1993] 1 CTC 185, 93 DTC 5099

Canada (Employment & Immigration Commission), [1991] 2 S.C.R. 22, 81 D.L.R. (4th) 358, Cuddy Chicks Ltd. v. ...
FCA

Her Majesty the Queen v. Apollo 8 Maintenance Services Ltd., [1991] 2 CTC 59, 91 DTC 5417

.: The motions judge allowed an extension of time for appealing a decision of the Tax Court under subsection 167(4) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
FCA

Henry Sokolowski and Elwira Sokolowska v. Her Majesty the Queen, [1996] 3 CTC 134, 96 DTC 6353

.: The attached reasons delivered in Sokolowska v. R. (Doc. A-633-95) also constitute the reasons of the Court in this appeal. ...
FCA

Cormie v. R., [1997] 2 CTC 259, 97 DTC 5210

’) for the 1987 taxation year on the basis that certain loans in the amount of $7,224,048.33 made by County Investments Ltd. ...
FCA

Hoedel v. The Queen, 86 DTC 6535, [1986] 2 CTC 419 (FCA)

Mileage incurred in transporting the dog was said to be 90 per cent of the total or 6,300 miles. ... The rationale for this provision, according to Sergeant Forbes, was "... to better socialize the dog". ...
FCA

Reiss Estate v. R., 99 DTC 5429, [1999] 3 CTC 660 (FCA)

The values of these parcels of land excluding the cost of sewage pumping stations ranged from $28,930/acre to $42,365/acre with an average of $35,647/acre. [...] ... Since I have determined that the total commercial portion of the property is 86,800 square feet, its total value at $12 per square foot is $1,041,600. [...] 1 have not considered as a separate item the cost to complete the sewer line to the subject property, calculated by Mr. ... C.A.), at 687. 5 /?. v. Eastern Trust Co. (1944), [1945] 4 D.L.R. 563 (Can. ...
FCA

King George Hotels Ltd. v. The Queen, 81 DTC 5082, [1981] CTC 87 (FCA)

The appeal from the trial judgment in that case (Appeal Division # A-347-80) was argued together with this appeal. ... (emphasis added) Appellant’s counsel contrasted the use of the words “carried on” in this Subsection with the words “from a source, in Canada... used in subparagraph 129(4)(a)(iii). ... There are, thus, various sources of income for such corporations but income derived from an active business is excluded a situation diametrically opposite to that encompassed by section 125. ...

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