Search - 深圳居住证 办理条件 最新政策

The report, however, was co-signed by the principal of R Hilton & Associates. ... Argument In a very efficient manner, Mr Cappell provided the Board with a summary of the points he wished to raise in argument and, since this summary is not only detailed but concise, it should be quoted: Notes for Argument on Behalf of Appellant — South Side — Best Location — Renovate — Proven Premium Value Same approach in two appraisals. ... No weight to Miller’s appraisal because — (a) he appraised the wrong property — see page 6 of his report; and (b) his “unconscious” bias is flagrant. ...

It was agreed between the parties that in 1974 the appellant had indicated in filing his tax return that only 50% of the disputed income should be for his account — again presumably the balance belonging to his wife. There was no other evidence or testimony which would substantiate the appellant’s contention — a point underscored forcibly by counsel for the respondent. In the appellant’s tax return for 1974, the following information was included: JAYLAND HOMES SCHEDULE OF TAXABLE INCOME MARCH 31, 1974 Add Deduct Reserve Reserve 20(1)(n) 20(1)(n) Net Income Income Tax Income Tax For Act Act Act Act Taxable % Year 1973 1974 Income Jetland Construction Limited 50 $242,076 $ 22,114 $ 51,839 $212,351 Vittorio Maggiori, Trustee 10 48,416 4,423 10,367 42,472 Northdown Drywall & Construction Limited 10 48,415 4,423 10,367 42,471 Jay-Win Investments Limited 10 48,416 4,423 10,367 42,472 Mark-Malcom Limited 10 48,415 4,423 10,367 42,471 Robland Estates Limited 10 48,415 4,422 10,367 42,470 100 $484,153 $ 44,228 $103,674 $424,707 As noted above, the taxpayer had included only the amount of $21,236 as such income from Jayland Homes. ...

To received from Alex Jovanovich — re: balance due on closing as per Statement of Adjustments $79,655.53 To paid to The Royal Bank of Canada — re: pay out of existing Agreement re Lodgement of Title Documents — as per telephone call made July 28/78 $22,544.23 To paid to E J Rutherford Real Estate Inc — re: balance of real estate commission 4,294.00 To paid to Hart & Parkhill — re: account for fees & dis bursements 380.29 To paid balance in trust a/c to Mr and Mrs Eelkema via deposit to a/c #518-598-8 at Royal Bank, Main Br, Strat ford — July 28/78 52,437.01 $79,655.53 $79,655.53 3.05 Moreover, from the amount of $52,437.01 deposited in the appellant’s bank account #518-598-8 at the Royal Bank, the appellant, on August 1, 1978, paid $20,000 to Stratford Truck Ltd as a loan. ... After the payment on his new home with the said sum, if he had borrowed money for his business needs (to reimburse the banks, etc — see para 3.04), then the interest on the borrowed money would have been deductible. The appellant contends that this is only a technical proceeding and that, in substance, the result is the same — he has to pay interest. 4.03.3 It is true that the final result is the same: the appellant has to pay interest. ...

The basic amounts in question from the assessment notices were: Additional Penalty on additional Monarch Unreported income tax assessed 1974 $ 7,896.90 $ 475.65 1975 14,626.59 1,169.05 1976 2,694.89 188.65 Bereskin 1973 $ 1,804.74 $ 216.94 1974 19,633.67 3,655.53 1975 4,041.91 562.12 The appellants, in their respective Notices of Appeal, represented the problem in this way: 1. ... There was no basis presented by the appellants upon which the Minister’s assessment of tax should be disturbed — see P Rawsthorne v MNR, [1981] CTC 2187; 81 DTC 116. ...

Yours very truly, Dunwoody & Company Per (Signature) JDD/hb J. D. ... In this respect, the following amounts will be added to your income: 1971 — $ 6,000.00 1972 — $ 7,000.00 1973 — $12,000.00 1974 — $12,000.00 Any further action will be held in abeyance for fifteen (15) days in order to allow you time to submit any information which you would like to have considered. Yours truly, (Signature) for Chief of Audit PF:hf In addition, the following information has been extracted by the Board from the financial statements of Oil Field which have been made available in the exhibits: Manage Gross Revenue Other ment Fixed Year (Given in $) Sales Income* Fees Assets (Net) Inventory 1955 $402,402 $101,695 $ 707 $15,197 $ 36,386 (8 mos.) 1956 216,913 215,713 1,200 17,352 54,978 1957 425,404 420,695 4,709 37,932 125,124 1958 487,024 480,568 6,456 45,855 94,222 1959 505,491 498,849 6,642 51,327 93,825 1960 418,568 412,524 6,044 41,998 150,808 1961 341,853 340,101 1,752 28,637 110,969 1962 468,323 467,229 1,094 26,918 111,840 1963 421,573 416,390 5,183 46,503 84,018 1964 330,981 325,159 5,822 35,905 71,785 1965 110,701 93,505 17,196 13,597 5,758 1966 3,965 2,556 1,409 10,529 10,114 1967 10,682 6,877 3,805 10,529 3,159 1968 1,408 1,044 364 Nil 2,694 1969 (not made available) 1970 Nil Nil Nil Nil 2 1971 5,600 600 Nil $ 5,000 Nil Nil 1972 7,160 552 608 6,000 Nil Nil 1973 13,585 Nil 2,085 11,500 Nil Nil 1974 14,563 2,563 12,000 Nil Nil Other Income consisted mainly of interest earned and discounts received. ...

In carrying out his business... the appellant incurred expenses in the aggregate amounts of 1974 — $4,478.08 1975 — 5,112.34 1976 — 9,506.01 The Minister of National Revenue... permitted the appellant to deduct expenses of $150 in computing his income from his business. ... In the end result, it was agreed between the parties that the following statements represented a summary of the amounts involved in the appellant’s contention that he was in business: 1974 EXPENSES — BOAT BUSINESS Type of Expense Amount Deducted Advertising, Promotion $ 239.69 Convention Expenses 265.32 Supplies, Materials 901.31 $1,406.32 1974 EXPENSES — DESIGN BUSINESS Type of Expense Amount Deducted Accounting, Legal, Collection $ 130,00 Automobile Expenses (gasoline, insurance, repairs) 1,078.97 Business Tax, Fees, Licences 25.00 Fire and Liability Insurance 33.00 Interest, Exchange, Bank Charges 2.00 Office Expenses, Postage, Stationery 87.50 Rent: 2/6 of apartment rent & hydro 1,169.22 Telephone, Light, Heat, Water 99.12 Other Expenses: subscriptions 26.00 $2,650.81 Aggregate $4,057.13 Minister has allowed $150. If succeed on Design Business — allow additional $2,500.81 If succeed on Boat Business — allow additional $1,406.32 If succeed on both — add $3,907.13 1975 EXPENSES — BOAT BUSINESS Type of Expense Amount Deducted Advertising, Promotion $ 281.45 Business Tax, Fees, Licences 52.00 Convention Expenses 705.63 Rent: Workshop 300.00 Supplies, Materials 654.01 $1,993.09 1975 EXPENSES — DESIGN BUSINESS Type of Expense Amount Deducted Accounting, Legal, Collection $ 100.00 Automobile Expenses (gasoline, insurance repairs) 970.13 Fire and Liability Insurance 33.00 Interest, Exchange, Bank Charges 6.00 Office Expenses, Postage, Stationery 122.15 Rent: 2/6 of apartment 1,180.00 Telephone, Light, Heat, Water 141.85 Capital Cost Allowance 400.00 $2,953.13 Aggregate claimed $4,946.22 Amount allowed by Minister $150.00 If succeed on design business, allow additional $2,803.13 If succeed on boat business, allow additional $1,993.09 1976 EXPENSES — BOAT BUSINESS Type of Expense Amount Deducted Advertising, Promotion $ 176.43 Business Tax, Fees, Licenses 58.50 Interest, Exchange, Bank Charges 189.42 Maintenance and Repairs (except automobile, truck) 90.00 Rent (workshop) 800.00 Supplies, Materials 2,343.74 $3,658.09 1976 EXPENSES — DESIGN BUSINESS Type of Expense Amount Deducted Accounting, Legal, Collection $ 125.00 Automobile Expenses (gasoline, insurance, repairs) 2,092.24 Fire and Liability Insurance 33.00 Office Expenses, Postage, Stationery 75.79 Rent: 2/6 of apartment 1,274.40 Telephone, Light, Heat, Water: 2/6 of $600.38 200.13 Travelling Expenses (except automobile) 1, 114.03 Capital Cost Allowance 1,341.15 $6,255.74 Expenses claimed $9,913.83 Allowed by Minister $443.90 If successful on design business — allow additional $5,701.84 If successful on boat business — allow additional $3,658.09 Evidence With regard to the “boat interest”, the appellant reviewed his long standing interest in boating, the associations to which he belonged over the years, and his particular interest in building a “racing boat” which was the type in question in these appeals. ...

Crops and Seeds — All Wheat $ 1,333.12 — Barley 1,117.90 2. Western Grain Stabilization Payments 25.57 3. Livestock Sold — Cattle (19) 7,386.81 4. Other Subsidies — Pipeline Easement 469.00 5. ... Law — Cases at Law — Analysis 4.01 Law The main provision of the Income Tax Act involved is subsection 31(1). ...

By notices of assessment dated May 3, 1977, the respondent disallowed the following expenses: In assessing the appellant for his 1973 taxation year the respondent disallowed the following expenses: (a) Mortgage Interest Claimed as Business Expense $2,805.38 (b) Bank Loan Interest Claimed as Business Expense $ 320.00 (c) Mortgage Fee $ 375.00 (d) Expenses for Office in Personal Residence $ 368.93 TOTAL $3,869.31 In assessing the appellant for his 1974 taxation year the respondent disallowed the following expenses: (a) Mortgage Interest Claimed as Business Deduction $3,691.21 (b) Bank Loan Interest Claimed as Business Expense $ 450.00 (c) Expenses for Office in Personal Residence $ 250.90 $4,392.11 and the Respondent also included the amount of $ 2,017.00 as income arising from an adventure in the nature of trade on the sale of a property known as 147 Merner Avenue, Kitchener. TOTAL $ 6,409,11 In assessing the appellant for his 1975 taxation year the respondent disallowed the following expenses: (a) Mortgage Interest Claimed as Business Deduction $3,626.75 (b) Bank Loan Interest Claimed as Business Expense $ 540.00 $ 4,166.75 and the Respondent also included the amount of $ 8,516.00 as the balance of a capital gain on the sale of a property known as 44 Walton Street, Kitchener. ...

At the hearing, the appellant testified as follows: In 1964, he became a shareholder of Robertson, Malone & Co Limited by investing $10,000 therein. ... His salary was nominal but, at the end of each year, instead of keeping the money in the company, the profit was shared amongst the shareholders and every year the appellant paid substantial tax thereon as appears in Exhibit A-7, as follows: INCOME AND TAXES PAID FOR PERIOD 1964-1971 Salary/ Bonuses Commissions Other Total Income Taxes Paid Salary/ 1964 $- $18,873 $- $18,873 $ 5,438 1965 16,227 — 16,227 3,655 1966 — 14,564 220 14,784 2,980 1967 478 21,680 (1,060) 21,097 5,918 1968 14,463 46,748 2,428 63,629 27,241 1969 71,443 18,000 (926) 88,516 42,574 1970 18,913 60,500 1,264 80,677 37,728 1971 43,801 10,500 1,581 55,882 22,125 From time to time, the appellant made several short-term loans to the company in order to comply with the Toronto Stock Exchange requirements. ... See Olympia Floor & Wall Tile (Quebec) Ltd v MNR, [1970] CTC 99; 70 DTC 6085 and Pigott Investments v The Queen, [1973] CTC 693; 73 DTC 5507 (above). ...

In subparagraph (e) he added after the word “delivered” the following words “and on quantity of fertilizers and supplies purchased... ”. 3.03 It was also admitted by both representatives of the parties that Mr Peter Kinnee had included in his income for the 1977 taxation year the amount of $1,227.61, and his son Mr Dennis Kinnee included the amount of $2,455.23, which are / and /3 of the amount received in cash as patronage dividends, the total is $3,682.84. 3.04 The T4-A forms issued by the Pool to the appellants are as follows: Peter Kinnee: $1,830.00 Dennis Kinnee: $7,333.49 Total $9,163.49 3.05 The amount of $5,480.65 ($9.163.49 of paragraph 3.04 less $3,682.84 of paragraph 3.03) is the sum that the appellants have not actually received and that the respondent has included in their income on the basis of the partnership / and %. 4. Law — Cases of Law — Analysis 4.01 Law The main legal provisions involved in the present case are section 135 and subsection 56(2) of the Income Tax Act and section 32 of the Alberta Wheat Pool Act 1970. ... Therefore they were illegally included in the appellants’ income by the respondent. 4.03.2 On the one hand, subparagraph 135(4)(g)(ii) of the Act quoted above, says that the word “payment” includes the “application by the taxpayer of an amount to a member’s liability to the taxpayer... pursuant to a by-law of the taxpayer, pursuant to statutory authority... ”. ...